Framework Service Contract for the Procurement of Studies
and other Supporting Services on Commission Impact
Assessments and Evaluations
Lot VI - Interim, final and ex-post evaluations of policies,
programmes and other activities
Interim Evaluation of the Measuring
Instruments Directive
Final report
July 2010
P O Box 159
Sevenoaks
Kent TN14 5WT
United Kingdom
www.cses.co.uk
Ref. Ares(2014)2787902 - 26/08/2014
Interim Evaluation of the Measuring Instruments Directive – Final report
Contents
Table of Contents
SECTION PAGE
Executive summary
1. Introduction 1
1.1 Objectives of the evaluation 1
1.2 Overall approach 1
1.3 Objectives of first findings report 3
1.4 Structure of the report 4
2. Methodology 6
2.1 Description of fieldwork 6
2.2 Interview programme 6
2.3 Market data collection 8
3. Market data analysis 10
3.1. Utility meters - general 10
3.2 MI-001 Water meters 10
3.3 MI-002 Gas meters 11
3.4 MI-003 Electricity meters 11
3.5 MI-004 Heat meters 12
3.6 MI-005 Measuring systems for liquids other then water 12
3.7 MI-006 Automatic weighing instruments 13
3.8 MI-007 Taximeters 14
3.9 MI-008 Material measures 14
3.10 MI-009 Dimensional measuring instruments 16
3.11 MI-010 Exhaust gas analysers 16
3.12 Summary table of market data 17
4. Analysis by sector 20
4.1 MI-001 Water meters 20
4.2 MI-002 Gas meters 21
4.3 MI-003 Electricity meters 21
4.4 MI-004 Heat meters 22
4.5 MI-005 Measuring systems for liquids other then water 23
4.6 MI-006 Automatic weighing instruments 25
Interim Evaluation of the Measuring Instruments Directive – Final report
Contents
4.7 MI-007 Taximeters 26
4.8 MI-008 Material measures 26
4.9 MI-009 Dimensional measuring instruments 27
4.10 MI-010 Exhaust gas analysers 27
5. Survey analysis 29
5.1 Analysis of notified bodies surveys 29
5.2 Analysis of SMEs survey 35
6. Main findings of the evaluation 41
6.1 Effectiveness of the MID 41
6.2 Impacts 46
6.3 Application and implementation 47
6.4 Strengths and weaknesses 51
7. Conclusions and Recommendations 53
7.1 Overall conclusions 53
7.2 Recommendations 54
APPENDIXES PAGE
A Interview programme 56
B List of references and sources 62
C Statistical correspondence tables 63
D Notified bodies survey questionnaire 65
E Measuring Instruments Analysis Tables 68
F Use of optionality by Member States 100
Interim Evaluation of the Measuring Instruments Directive – Final report
Abbreviations
List of abbreviations used in the text
AQUA- European Association of water and heat meters manufacturers
AWI – Automatic Weighing Instruments
CAs – Competent Authorities
CECIP - European Committee of Weighing Instruments Manufacturers
CECOD - European Committee of Manufacturers of Petrol Measuring Systems
CEN – European Standardization Committee
CENELEC – European Committee for Electro-technical Standardization
CEO -European Hand Tools Association
EGEA – European Garage Equipment Association
EN – European Norms
ESMIG - European Smart Metering Industry Group
EURELECTRIC/UNIPEDE, Union of the Electricity Industry
FACOGAZ, Association of European Gas Meters Manufacturers
FEVE – European Container Glass Association
MIs – Measuring Instruments
MID – Measuring Instruments Directive 2004/22/EC
MOT – Ministry of Transport. Used to refer to test stations that carry out vehicle tests for road safety
and environmental standards
NAWI – Non-Automatic Weighing Instruments
NB – Notified Bodies
NLF- New Legislative Framework
OIML – International Legal Metrology Organisation
PRODCOM – Products of the European Community – EUROSTAT Database
POS – Points Sale
SSD – Self Service Devices
WELMEC –European Legal Metrology Cooperation
wgMI – European Commission working group on Measuring Instruments
Interim Evaluation of the Measuring Instruments Directive – Final report
Executive summary
i
This summary contains the main conclusions and the recommendations of the study ‘Interim Evaluation
of the Measuring Instruments Directive’. The study was conducted by the Centre for Strategy &
Evaluation Services (CSES) LLP during the period November 2009 – July 2010 for the European
Commission Directorate General Enterprise and Industry.
I. Introduction
The Directive 2004/22/EC of the European Parliament and of the Council of 31 March 2004 on
measuring instruments (MID) has been operational since October 2006. It ensures the free movement of
measuring instruments in the internal market and applies to the following instruments defined in the
Annexes to the Directive:
• water meters (MI-001);
• gas meters and volume conversion devices; (MI-002)
• active electrical energy meters; (MI-003)
• heat meters; (MI-004)
• measuring systems for continuous and dynamic measurement of quantities of liquids other then
water; (MI-005)
• automatic weighing instruments; (MI-006)
• taximeters; (MI-007)
• material measures; (MI-008)
• dimensional measuring instruments; (MI-009)
• exhaust gas analysers (MI-010).
Under Article 25 of the Measuring Instruments Directive the Commission was invited to report, before
30 April 2011, on the implementation of this Directive on the basis of reports provided by the Member
States, and, where appropriate, to submit a proposal for amendments.
As part of the response of the Commission, an evaluation study was commissioned aiming to compile,
assess and present information on the implementation and functioning of the Directive in terms of its
impacts and application, in order to define the potential for improvement.
The objectives of the evaluation, as set out in the terms of reference, are to:
• Provide a quantified table of approximate figures for each of the 10 sectors and subsectors of the
measuring instruments (MIs) listed.
• Assess, to this point, the effectiveness of the Directive, and more specifically:
o the extent that the Directive contributed to an efficiently operating internal market for the
goods in question
o the extent that the Directive influences technological innovation and to what extent it has
contributed to the development of innovation
Interim Evaluation of the Measuring Instruments Directive – Final report
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ii
o the extent that the Directive achieved its aims with regard to the protection of consumers
and users
o the extent that a two tier market concerning consumer protection and competition has
developed, and to assess if there is difference where Member States have not opted to
require Legal metrological control (optionality)
o the participation of non-government stakeholders in the measuring instruments committee
and their impression as well that of others as regards their participation
o the overall strengths and weaknesses of the Directive
• Assess the impacts of the Directive on markets and European companies in terms of costs or
administrative burdens and of tangible benefits
• Assess the implementation of the Directive in the Member States and identify the barriers to
effective application of the Directive and the ways that such barriers could be overcome
• Identify measures that could be taken to improve the utility of the Directive and the expected role
of the adaptation of the new approach (omnibus) to its implementation
It should be noted that this evaluation did not examine issues related to specific proposals by
stakeholders and the inclusion of additional categories of instruments in the MID. This is an exercise that
falls under the scope of a separate study commissioned by the European Commission.
In order to carry out this assignment, CSES used a combination of research tools including a review of
relevant documents and publications, collection and analysis of market and other data from a range of
public and private sources and 91 interviews with the main stakeholders related to the Directive
(Member States’ competent authorities, industry associations and companies active in sectors covered
by the MID, standardization bodies, SMEs and consumer representatives and legal metrology experts). It
also organised a survey of the notified bodies that conduct the tests for the provision of conformity to
the requirements of the Directive and used the data of the SME panel survey that was organised by the
Commission services.
II. Market of legal metrology instruments covered by the MID
Based on the information and data collected it is estimated that the MID applies to 345 million units of
MIs that are sold annually in the European market with a total sales value of €3.25 billion. Around 300
million units concern the small value category MI-008 instruments (material measures including
measures of length and capacity serving measures). In terms of value, close to 50% of the total market in
terms of sales concerns utility meters (water meters, gas meters, electricity meters and heat meters)
while automatic weighing instruments represent around 17% and material measures 14.3% (see Table
1).
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Table 1 – Total size of market covered by the MID
Market size – number
of items sold annually
(000s)
Market size- value
of items sold
annually
(million €s)
Share in total
MIs market
Employees
occupied in
sector
(1000s)
MI-001: Water Meters 18,000 450 13.8% 25
MI-002: Gas Meters &
Conversion Devices 6,900 410 12.6% 30
MI-003: Active Electricity
Energy Meters 14,000 610 18.8% 32
MI-004: Heat Meters 800 290 8.9% 18
MI-005: Measuring Systems
for Liquids other than Water 31.2 240 7.4% 14-16
MI-006: Automatic Weighing
Instr. 21 550 16.9% 25
MI-007: Taximeters 50 25-40 1% 1
MI-008: Material Measures1 300,000 440-490 14.3% 34
MI-009:Dimensional
Measuring Instr. 300-400 70-80 2.3% 7
MI-010: Exhaust Gas
Analysers 25-35 130 4.0% 17.5
Total 345,000 3,250 100% 190
The data collected indicates that there are 900 active manufacturers in one or more of the 10 MI
sectors. Some sectors, mainly the utility meters, are dominated by a few large multinational companies.
In others, such as the automatic weighing instruments or exhaust gas analysers, there are a larger
number of small and medium size enterprises. The total number of employees is estimated at 190,000.
The above number does not include SMEs that operate mainly as distributors, importers of instruments
or provide repair services.
Finally, data collected on the level of trade of MIs suggest that 20-25% of MIs in the EU27 are imported
while 25-30% of the MIs produced in the EU27 are exported to third countries. There is important
variation among the different categories of MIs. Trade levels in both directions are particularly high
(over 50% of total) for the less technology intensive categories of material measures (MI-008) and
dimensional measuring instruments (MI-009) but also for electricity meters (65%). At the same time, the
share of production exported is particularly high in the case of more advanced technology instruments
such as Automatic Weighing Instruments (up to 42% for the sub-category of automatic gravimetric filling
instruments) and in the Gas Meters category (44%) where EU firms are the world leaders.
1 Data refer to all material measures of length in the market. Not only MID certified.
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III. Overall findings of the evaluation
Effectiveness of the Directive
The conclusions of the analysis is that, up to this point, the MID has rather successfully provided the
basis for the development of a more efficiently operating internal market through the use of a single
certificate. The contribution of the MID in this respect is recognised by the great majority of
stakeholders (competent authorities, notified bodies, firms) and the current situation is seen as a
significant improvement in relation to the pre-MID period that had been dominated by multiple national
legislations with important differences that posed important trade barriers.
Having said that, the initial period of the implementation of the Directive has been characterised by
problems in a few sectors covered by the MID, that have limited its effectiveness. These include:
• Barriers posed by some national and local authorities by setting additional requirements or, in some
cases, regulations concerning functionality, marking or the use of instruments. In the majority of the
cases, they are issues which are not governed by the MID and concern the use of MIs after they are
placed in the market. In relation to legal metrology instruments, Member States give, in general,
greater priority to consumer protection and other requirements concerning the use of instruments
than any possible obstacles to the smooth operation of the single market. As a result, in a number of
occasions their introduction imposes requirements that limit the benefits of a single MID certificate.
• Controls and requirements applied by a few national authorities that reflect practices of old national
regulations that indicate a possible problem of understanding – or possibly accepting - what the
implementation of a new approach Directive entails.
• Limited information on the applicability and requirements of the MID for a number of
manufacturers and, more often, importers of measuring instruments. However, the evidence
collected does not indicate that the problem is particularly acute.
• Sector specific problems that have a negative impact on the market for fuel dispensers and other
liquid dispensing systems. They concern the limitations in combining new and old components for
upgrading existing instruments or systems (mix and match problem). The industry reports a negative
impact on the operation of the market in some Member States and a limited uptake of MID-certified
instruments as a result. Furthermore, small size producers of self-service devices or components
appear to be in an unfavourable position against large firms that develop and sell complete systems.
Issues related to the use of modules and sub-assemblies are also reported in the case of automatic
weighing instruments and for utility meters although there is no evidence of significant negative
impacts on the operation of the market.
With the exception of the sub-assembly issue, most of the problems mentioned could be considered as
symptoms of an initial “teething period” and it should be expected that the number of problems will
reduce as experience builds up.
Parameters and barriers that have an impact on the effective implementation of the Directive
The quality of market surveillance appears to be one of the important concerns of industry and it is an
area where most authorities recognise that their effort has so far been rather limited. Up to now most
authorities concentrate on checking whether the CE+M mark is properly affixed and that the necessary
Interim Evaluation of the Measuring Instruments Directive – Final report
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paperwork is conducted. According to a few reported cases even such typical tests are not always
properly performed.
The absence of proper surveillance appears to be the main reason for almost all, still limited, occasions
of unfair competition reported. The authorities in most Member States refer to limited resources
available as the underlying reason for the ineffective control of the market. Still, there is no evidence of
a particularly problematic situation either in terms of consumer protection or in terms of the gradual
development of a single market.
A second parameter is the operation of the notified bodies in the assessment of conformity and the
overall certification procedures. Some notified bodies tend to use WELMEC guidance documents as if
they represent regulations and, in a few occasions, they present obstacles to companies that follow
alternative approaches. At the same time notified bodies are also reported as rather inconsistent in their
operation with important variations in the capacity to carry the necessary tests, especially those in the
new Member States. Given their key role in the conformity assessment procedure and their contact with
manufacturers, such problems can create confusion in the application of the Directive.
On the positive side, the use of normative documents developed based of OIML recommendations have
contributed on the implementation Directive and their use is considered appropriate by almost all
stakeholders. Most of these documents were used even before the MID and they help to keep Europe in
line with the rest of the world. They reduce the risk of creating technical barriers and help international
trade. Problematic areas do exist though and the level of harmonization with European standards –
where they exist – is still not complete for some categories of instruments.
Despite the problems related to the use of its guidance documents by the notified bodies, WELMEC2 has
a positive contribution towards the effective implementation of the Directive. The guidance
documents issued cover the full range of activities and address all different stakeholders involved. The
working groups of WELMEC provide the appropriate forum for the identification of any issue and
problem related to the implementation of the MID and for the formulation of the relevant proposals for
consideration based on the broadest possible consensus.
Role of the Directive in promoting or inhibiting technological innovation
The empirical evidence indicates that in most categories of instruments the MID has not affected
technological innovation to any material extent. In general the MID appears to be technologically
neutral allowing for a level playing field. The economic incentives for easier access to a broader market
was the only benefit stated and only in a few occasions.
A few areas where rather minor problems in relation to technological innovation are still present:
• A common problem seems to be the restrictive use by the notified bodies of WELMEC guidelines
and the constraints that almost all stakeholders see in accepting alternative approaches to conform
2 WELMEC –European Legal Metrology Cooperation is the organisation of national authorities in legal
metrology at which meetings some stakeholders participate.
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to the essential requirements of the Directive. They are seen as posing more stringent and limiting
requirements to the firms that chose not to follow the guidelines, beyond what companies and
some trade associations consider justified.
• The essential requirements for some categories of MIs are seen as restrictive or prescriptive.
Industry and some of the competent authorities refer to limitations in terms of the classes and types
of instruments allowed (e.g. exhaust gas analysers only for cars – MI-010) and concerning the
opportunities for market trials in the case of fuel dispensers (MI-005).
• An issue specific to the utility sector concerns the use of smart meters where the dominant view is
that the current provisions of the Directive do not provide an optimal solution in view of the
technological and market developments in place. However, the smart meters regulation has
implications than go further than purely metrological issues. As a result, further experience and
analysis is necessary.
Evidence of the development of two tier market and unfair competition – role of optionality
The optionality clause of the MID has been used by a number of countries (See Appendix F) although,
still, for 90% of the total3 category of MIs a national legislation in accordance to the MID is in place.
According to the most recent reports, 17 countries have opted out from the Directive for one or more
instruments. The main reasons for selecting to opt out concern either the absence of specific categories
of legal metrology instruments from the market or the consideration that the administrative burdens
imposed would be much higher than the additional level of consumer protection provided.
While a number of stakeholders have expressed their disagreement with the principle, the evidence is
that, until now, there have been no problems in terms of unfair competition or a two-tier market. The
only area where optionality was linked with unfair competition concerned taximeters but, again, the
evidence was limited.
Two tier markets – wherever present - do not seem to be a result of the use of the optionality principle.
Two tier markets are present for some categories of instruments that are also used for non-legal
metrology purposes (e.g. weighing instruments, material measures, dimensional measuring), for
example as parts of the production process of companies or in households. Such non-legal metrology
instruments may be identical to instruments covered by the MID, but their placement in the market is,
according to article 2 of the MID, not controlled by national regulation as far as metrological issues are
concerned. Accordingly, parallel markets shall be expected to continue in the future irrespective of the
MID and the use or not of optionality without posing any problems to the operation of the MIs market.
Contribution to the protection of consumers and users – role of optionality and other factors
The evidence available indicates that the Directive has, in most cases, not led to significant changes to
the level of consumer protection provided and there is no evidence that optionality has jeopardized
consumer protection. On the contrary, in a few countries – mainly new Member States - the
implementation of the Directive has helped to increase the standards applicable to some MIs.
3 857 of the total of 972 reflecting 27 Member States multiplied by 36 categories or subcategories of MIs.
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Consumer protection problems, where applicable, are primarily connected with the poor market
surveillance in some countries or MI sectors that allows the entry and circulation of non-certified
products in the single market.
Effective representation in the Measuring instruments decision making procedures
The general picture is that the MID decision-making procedures are open for input, comment and
contribution to all interested stakeholders. There is no evidence that interested parties have been
excluded or that they did not have the opportunity to raise issues properly. Among the sectors that are
not directly represented (mainly concerning categories MI-007 to MI-010) the interviewed companies
did not consider this as problematic although there is still scope for greater level of representation.
As far as representation of SMEs and consumers are concerned, the MID appears to be low priority for
their representatives and no concerns or issues were raised.
Impacts in terms of costs or administrative burdens and tangible benefits
The implementation of the Directive has provided opportunities for cost cuttings based on the use of a
single certificate. In some cases, the establishment of quality systems have also brought financial
benefits on a medium to long-term horizon.
But at the same time, there is evidence that the introduction of the MID has led to increases in the fees
charged by notified bodies due to more thorough tests and that it has in general extended the length of
the certification procedures. In contrast, the envisaged competition among notified bodies has not
developed yet. Based on the information provided, the fees charged by notified bodies for a single
certificate have increased in some countries by up to 30%.
Brought together, the introduction of the MID seems to have led to some cost savings in relation to the
previous situation. These savings appear rather moderate and tend to be unevenly distributed,
favouring firms with higher level of exports and with presence in multiple markets. Firms that are only
active in the respective domestic markets may experience higher administrative costs depending on the
type of instrument and the conformity assessment procedures followed.
Impact on SMEs
The analysis indicates that small and medium size firms are, in general, neither advantaged nor
disadvantaged as a result of the implementation of the MID. In two sectors (MI-005 and MI-006) the
industry representatives argue that the absence of a modular approach (certification of components or
sub-assemblies) may operate against SMEs that focus on the development of only parts/components
that cannot be certified. However, the SME survey did not provide strong evidence of widespread
problem. Only one out of 286 respondents made such reference.
More generally, the results of the survey do not indicate that SMEs experience barriers to entry in the
market for MIs. Nor was there any evidence that the introduced conformity assessment procedures are
particularly burdensome.
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viii
Expected role of the adaptation of the new approach (New Legislative Framework - NLF) to the
implementation of the MID
The adaptation of the new approach (New Legislative Framework) is expected to bring changes in the
implementation of the Directive.
On the positive side, the NLF is expected to improve the level of market surveillance based on the
requirement for the development of a surveillance plan by member states. Furthermore, the new
information exchange obligations posed by the NLF should help address the inconsistencies among the
140 notified bodies described earlier. However, it remains unclear how the NLF provisions will be
implemented given that many competent authorities refer to limited resources as the main underlying
issue.
On the possibly more negative side, changes in the language requirements as a result of the NLF may
create additional costs to manufacturers. The NLF creates a possibility – although not a requirement -
that Member States’ authorities may require full documentation in their own language. Such a
requirement may pose additional costs to companies and - probably in only few extreme cases - may
lead firms that trade only a small number of instruments in a Member State to exit the specific market.
Main strengths and weaknesses of the Directive
Based on the analysis, the evaluation identified the following strengths and weaknesses in the
implementation of the MID up to now.
Strengths
• The introduction of the MID has successfully provided the basis for the development of a more
efficiently operating internal market through the use of single certificate that allows the placement
of MIs in the market.
• Overall, the MID has proven a technologically neutral directive and has not created obstacles to
technological innovation. There are some issues related to the use of software in some categories of
instruments and of smart meters in utilities, but these are well documented through WELMEC
working groups and efforts to identify the appropriate solution – through guidance documents,
standards or amendments are examined.
• The optionality principle appears to be a strong point of the Directive. There is, at least up to now,
no evidence that its use by Member States has led to unfair competition or to a two-tier market in
the area legal metrology instruments. At the same time, the flexibility provided to Member States
appears to be an important factor in achieving agreement in key areas.
• The level of representation of the most affected stakeholders appears appropriate and, while
industry does not have voting rights, WELMEC working groups and the MID working group are
sufficiently open and provide the opportunity for the issues to be properly raised and argued.
• The involvement of WELMEC and the various working groups represent also an important asset for
the successful implementation of the Directive. It provides a forum for identifying and discussing the
various technical issues and other problems. The guidance documents issued are considered by the
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majority of stakeholders as useful tools for the interpretation of the essential requirements and the
conformity assessment procedures by manufacturers and notified bodies.
Weaknesses
• The low level of market surveillance is one of the key weaknesses of the implementation of the MID
to this point and it appears to be the main reason for the development of two tier markets and
unfair competition in some sectors and some Member states.
• The inconsistency of notified bodies in the interpretation of essential requirements and WELMEC
guidance documents also represents a weak point of the implementation of the Directive. As it
appears, the capacity of the 140 notified bodies varies and they tend to follow different approaches.
This leads to great variation in the experience – in terms of time and cost - of manufacturers during
the certification process. The issuing of WELMEC guidance documents only in the English language is
proposed by some bodies as contributing, to a certain extent, to these inconsistencies.
• The level of information concerning the Measuring Instruments Directive is problematic and a
number of companies– manufacturers and more often importers – are still not properly informed of
the applicability and requirements of the Directive. The absence of information should however be
seen in the context of a perceived limited impact and relevance of the Directive in some sectors (e.g.
capacity serving measures, taximeters) and the low priority attached by the respective trade
associations.
• The information exchange among competent authorities and notified bodies in relation to
instruments certified or rejected is still problematic and represents an additional barrier towards
more effective market surveillance.
IV. Recommendations
Based on the results of the evaluation, it is concluded that no actions toward amending basic provisions
of the MID are necessary.
In relation to the issues raised by the European Parliament, there is no apparent need for changes in
relation to the optionality principle, as there is no evidence that it has distorted competition or
created two-tier markets of legal metrology instruments.
At a more practical level, the utility and effectiveness of the Directive can be improved if actions by the
Commission and/or the Member States in relation to the following issues take place:
• Improve the coordination and strengthen the quality of accredited notified bodies by enhancing
information and experience sharing and providing training or other relevant support in relation to
the application of conformity tests, the interpretation of the essential requirements and the use
of WELMEC guidance documents. The provision of translated versions of the various WELMEC
guidance documents could also play a positive role. If WELMEC does not have the necessary
resources, Member States should probably take this responsibility. The New Legislative Framework
is expected to provide the legal context for information and experience exchange but the
Commission and the Member States should aim to promote such activities and bring together the
notified bodies and experts from WELMEC even before the NLF regulation is applied.
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• Strengthen the effectiveness of market surveillance by developing and implementing market
surveillance plans and ensuring that the necessary resources to implement these plans are
earmarked. The Commission can help in sharing results and experience among the relevant bodies
through the organisation of targeted discussion groups or forum. In this regard, it would also be
helpful if Competent Authorities prepare annual plans including their objectives and the resources
to be used and to share these plans with each other and the Commission.
• Increase the level of information exchange among competent authorities concerning instruments
certified or rejected. The existing system for accessing EC type certificates through the web pages of
13 Member States represents a useful tool in facilitating exchange of information among Member
States authorities and notified bodies. The development of a single database bringing together all
information on certification activity could provide the most effective and coherent solution. It is still
not the only possible option, provided that Member States make the information available and
adopt a consistent approach for its presentation.
• In relation to that, it is also recommended that a common certificate format for each category of MI
be developed– possibly by WELMEC – to be adopted by all notified bodies.
• The Commission and the Member States should consider proportionate measures to increase the
level of awareness of the Directive by manufacturers and importers through the implementation of
targeted information campaigns in cooperation of key stakeholders at the European and national
level.
• Given the presence of specific gaps in the representation of some of the sectors covered by the MID
(i.e. gas analysers, capacity serving measures) the Commission should repeat its invitation to other
relevant European trade associations. The European Garage Equipment Association and the
European Container Glass Federation are two such stakeholders identified during the course of the
study.
Finally, the findings of the evaluation indicate the presence of a number of issues concerning specific
categories of instruments. The most problematic area is the combination of old and new components
for liquid dispensers other than water (MI-005). The recommendation of the evaluators is that the
Commission and the Member States attempt to identify a solution to the problem rather than simply
to wait for the end of the transition period. It is quite possible that the end of the transition period will
not lead to the solution of the reported problems. It is outside the scope and the expertise of the
evaluators to propose a specific solution – including an amendment of the MID, a guidance by the
Commission or WELMEC or some other fix - given the technical character of the issue. The existing
representation bodies, including WELMEC and the working group of the Directive, appear to provide the
appropriate forum for discussing and addressing this issue and this process is already ongoing.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Introduction
1
1
This document contains the final report submitted by the Centre for Strategy & Evaluation Services (CSES)
LLP in respect to the assignment: ‘Interim Evaluation of the Measuring Instruments Directive’.
1.1 Objectives of the evaluation
The objectives of the evaluation, as set out in the terms of reference, were to:
• Provide a quantified table of approximate figures for each of the 10 sectors and subsectors of the
measuring instruments (MIs) listed with focus on establishing information on turnover, trade,
employment and number of firms active, including manufacturers, importers and distributors.
• Assess, to this point, the effectiveness of the Directive, and more specifically:
o the extent that the Directive contributed to an efficiently operating internal market for the
goods in question
o the extent that the Directive influences technological innovation and to what extent it has
contributed to the development of innovation
o the extent that the Directive achieved its aims with regard to the protection of consumers
and users
o the extent that a two tier market concerning consumer protection and competition have
developed and if there is difference in the case of Member States have not opted to require
Legal metrological control (optionality)
o the participation of non-government stakeholders in the measuring instruments committee
and their impression as well that of others as regards their participation
o the overall strengths and weaknesses of the Directive
• Assess the impacts of the Directive on markets and European companies in terms of costs or
administrative burdens and of tangible benefits.
• Assess the implementation of the Directive in the Member States and identify the barriers to
effective application of the Directive and the ways that such barriers could be overcome.
• Identify measures that could be taken to improve the utility of the Directive and the expected role
of the adaptation of the New Legislative Framework to its implementation.
1.2 Background to the evaluation – key issues raised by the European Parliament
The MID Directive was initially proposed by the Commission in 2000. It is a New Approach Directive that
is based on the adoption of essential requirements applying to a range of devices and systems with a
measuring function. It covered 10 categories of measuring instruments and intended to abolish the 17
corresponding old approach Directives. The MI covered devices and systems with a measuring function
concerning water meters (MI-001), gas meters and volume conversion devices (MI-002), active electrical
energy meters (MI-003), heat meters (MI-004), measuring systems for continuous and dynamic
measurement of quantities of liquids other then water (MI-005), automatic weighing instruments (MI-
006), taximeters (MI-007), material measures (MI-008), dimensional measuring instruments (MI-009)
and exhaust gas analysers (MI-010). The MID intended to harmonise the technical rules across the EU
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Introduction
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while the instrument manufacturers were given the opportunity to develop and get accreditation for
quality systems that would allow them to carry out the initial verification themselves rather than having
to use the services of Authorities. It required the Member States to adopt a common system of
Conformity Assessment.
Following a four year period of readings in European Parliament and Council and two amended
proposals by the Commission, the Council and the European Parliament adopted the Directive on
Measuring instruments (MID) in 2004 (Directive 2004/22/EC) that came into effect on the 30 October
2006. Member states were given a period of two years – until 30 April 2006 – to transpose the Directive
into national legislation.
This interim evaluation of the Measuring Instruments Directive supports the European Commission in
fulfilling the requirement set by the revision clause of the Directive proposed by the European
Parliament asking for a report in the implementation of the Directive before 30 April 2011. This revision
clause was motivated by a number of concerns of the Parliament that are addressed in the evaluation.
These concerns are described in brief below.
Key issues raised by European Parliament related to the implementation of the Directive
Use of optionality principle and impacts on single market and consumer protection
The first issue flagged by the European Parliament concerned one of the distinguishing features of the
MID, namely the presence of the ‘optionality clause’ that allows Member States to choose for which
tasks they require legal metrological control in which case only instruments conforming with the
Directive may be used. Where a Member State does not require legal metrological control, it cannot
impose any other controls and may not place barriers to any instrument to circulate freely in the
market. The concerns of the European Parliament in relation to optionality was that as some Member
States may consider that legislation is not necessary in their territory this may lead to unequal consumer
protection. Furthermore, the fact that legal metrological control is not required for all conceivably
possible uses means that there is a possibility of a dual market to develop consisting of measuring
instruments conforming to the MID and other instruments. In the opinion of Parliament, this may lead
to unfair competition between manufacturers and importers that supply to the regulated markets with
those that supply to the unregulated markets. Furthermore, the optionality clause was also considered
as possibly creating unequal treatment to consumers in the different Member States given the
application of different standards.
The evaluation study examined in depth the possible issues linked with optionality - development of
dual markets, unfair competition, consumer protection, problems related to market surveillance.
Technological innovation
A second issue related to the role of the Directive in promoting or hindering innovation and
technological change. While the new approach performance requirements are intended to provide
flexibility to manufacturers and enhance technological innovation, there were concerns raised by the
Parliament as to the extent that the rapid pace of technological change in the measuring instruments
generally, and in some particular sectors and sub-sectors, had been adequately taken into consideration
in the setting of the essential requirements.
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Introduction
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Representation in the Measuring instruments committee
A third issue was the role and the structure of the Measurement Instruments Committee. The main
concern was whether level of representation of industry associations and other stakeholders in the
decision making procedures was adequate. Following Article 15 of the Directive, the MIs Committee is
made up of the relevant authorities from the Member States. Other parties such as industry, non-
governmental organisations or non-Member States stakeholders do not have a formal role in the
Committee even if they have a clear stake in the Directive. However, the Committee is required to
consult with representatives of interested parties.
Application of conformity assessment procedures
A final issue raised by the Parliament concerned the application of the conformity assessment
procedures and the extent to which there has been a consistent application of the conformity
assessment procedures among Member States and whether there were deviations from the format
proposed in Council Decision 93/465/EEC. However, since then the implementation of the Omnibus
process to adapt the MID to Decision 768/2008/EC (New Legislative Framework) is expected to address
this points of criticism by creating a common framework for the marketing of goods and by
standardising procedures horizontally.
The above questions of the European Parliament are addressed in this study as part of the key
evaluation questions of utility, effectiveness and impact of the Directive.
1.3 Overall Approach
The approach adopted for the organisation of the Evaluation of the Measuring Instruments Directive
followed three stages:
Phase 1: Preparatory Tasks – Phase 1 included a set-up meeting and various preparatory tasks including
Commission interviews, a review of available documents, and review of potential external reports and
data sources, attendance at a working group meeting. It was completed with the submission of an
inception report presenting in more detail the methodology and the tools (interview programme,
interview checklists, questionnaires and data sources) that were during phase two of the study. The
Inception report was submitted on the 14th
of December 2009 and was approved by the Commission
with comments.
Phase 2: Fieldwork – Phase 2 involved the purchase of external market reports as agreed, carrying out
the interview and survey programme and an analysis of each sector based on information collected.
There was also an overall assessment of the implementation of the MID. It concluded with a first
findings report outlining initial findings and recommendations;
Phase 3: Analysis and Final Report – during the final phase, the research findings were subject to
further analysis based on the comments of the Steering Committee. A draft final report was prepared
and submitted on the 25th
of June 2010 and the key findings and recommendation of the evaluation
were presented during the working group meeting on 1 July 2010 in Brussels. The feedback and
comments received have been integrated in this final version of the report.
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The following diagram summarises the methodological approach and work plan used for the study.
1.4 Structure of the report
The report is structured as follows:
Section 1: Introduction – presents the objectives of the evaluation
Section 2: Methodology – presents the approach adopted for examining the key evaluation questions
and the methods and tools used for the collection of data and information and for analysis
Section 3: Market data analysis – presents approximate figures for each of the sectors and subsectors
of the measuring instruments.
Section 4: Analysis by sector - Presents an analysis of the information and data collected from the
interview programme and the literature review for each measuring instrument sector in relation to the
key evaluation questions.
Section 5: Survey analysis - Presents an analysis of the two surveys, of notified bodies and of SMEs
Phase 1
Preparatory Tasks
•Set-up meeting
•Participation in working
group meeting
•Analysis of key documents
•Review of available data
sources
•Development of
methodology and research
tools
•Preparation of inception
report
•Phase 1 review meeting
Phase 2
Data collection,
interviews and
analysis
Phase 3
Delivery and final
report
•Completion of analysis
and validation of results
•Preparation of final report
•Presentation to
Commission staff and MID
stakeholders
•Review of documents and
literature
•Collection of data and
preliminary analysis
•Interview programme
•Progress report
•Participation in Working group
meeting of 11 March
•Analysis of findings and
provisional conclusions
• Preparation of first finding
report
Inception report
14 December 2009
First findings report
28 May 2010
Final report
25 June
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Introduction
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Section 6: Overall findings of the evaluation – Provides a synthesis of the findings of the study and
addresses the key evaluation questions posed in the terms of reference.
In this section we present the conclusions of the study in relation to the key evaluation questions. The
effectiveness, impact and implementation of the Directive – especially in relation to the issues raised by
the European Parliament – are addressed based on the findings presented in the previous sections
Section 7: Overall conclusions and recommendations – Presents the overall conclusions of the analysis
in relation to the key evaluation questions and presents a set of recommendations for moving forward
The main body of the report is supported by a list of Appendixes that include:
Appendix A - Interview programme by type of stakeholders and category of MIs covered
Appendix B – List of the documents and other sources reviewed
Appendix C – Correspondence table of EUROSTAT PRODCOM database classification codes with the
measuring instruments categories
Appendix D – Notifies bodies survey questionnaire
Appendix E – Analysis of key evaluation questions by category of MIs
Appendix F - information on the use of optionality by the Member States
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Methodology
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In this section we present the work conducted during the second phase of the study including the
interview programme, the survey work and the analysis of the relevant literature.
2.1 Description of fieldwork
Phase 2 of the assignment involved carrying out the core tasks of the project. These tasks included
activities focusing on the different categories of measuring instruments and activities that cover the
project overall.
Table 2.1 – Main elements of fieldwork
For each category of MIs Overall
- Literature review of relevant documents
submitted by trade associations and other
stakeholders
- Data collection based on market reports,
statistical databases, trade associations and
other sources
- Interviews with WELMEC working groups’
convenors, trade associations and companies
from each MI sector
- Literature review
- Interviews with competent authorities,
WELMEC working group convenors, standard
bodies’ representatives
- Survey of MID accredited notified bodies
- SME panel survey on the implementation of
the Directive
For each category of measuring instruments, we carried out an analysis of the relevant literature and
the interview programme including trade associations (if existing), manufacturers and users. Twelve
sectors were examined separately for the 10 groups of MIs covered by the MID. Fuel dispensers (petrol
pumps) that fall under MI-005 and tapes/dip sticks under MI-008 were examined separately due to the
presence of trade associations representing these subsectors.
The literature review on each sector concerned information and documents identified in Phase 1, any
reports we received from stakeholders during the fieldwork, and any other documents from the
members of the working group of Measuring Instruments (wgMI) were made available through CIRCA.
Additional documents concerning some of the categories of MIs as a result of a web search.
Data collection and analysis was, depending on the sector, based on the combination of market reports
purchased in the beginning of Phase 2, data from EUROSTAT, information from trade association and
other industry representatives and the Member States’ legal metrology authorities.
In response to the study requirements, CSES aimed to collect figures on turnover, employment size and
number of firms for each sector of MIs analyzed at the European Union (EU27) level. However, data was
not available for all sectors and all categories. In this case, estimates were made and the underlying
assumptions and calculations presented.
2.2 Interview programme
The interview programme included telephone – mainly – and a few face to face discussions with a
number of different stakeholders including Member States competent authorities, Trade Associations of
manufacturers or importers wherever available (primarily at the European level), individual
manufacturers, importers and users (e.g. utility firms). It also included European and international
standard bodies, members of WELMEC working groups and representatives of SMEs and consumers.
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The initial target of the interview programme was 100-112 interviews including 4-5 interviews per MI
sector. The preparatory work in Phase 1 and the additional search during the fieldwork identified 127
interview targets from industry/trade associations and firms (manufacturers and/or importers) ranging
from 6 to 17 per sector (the detailed list is presented in Appendix C). All these targets were contacted by
email or telephone in an attempt to identify the appropriate contact person.
By the end of the fieldwork period 91 interviews were completed (see Table 2.1). In terms of the
interviews with competent authorities most MS were covered by at least one interview with the
exception of five that declined our invitation. All interviews with the relevant WELMEC working groups’
convenors and standard bodies (CEN and CENELEC) were also completed.
One issue was the geographical distribution of the companies in each sector. The objective of the
interview programme was to achieve a broad geographical coverage and avoid interviewing more than
one company from the same country. The target list (see Appendix A) covered companies across Europe.
However, in some sectors the interview participation rates were very low. This was particularly the case
among companies in Eastern Europe countries, possibly due to language constraints. As a result, in some
sectors there is a focus on companies from old member states.
Table 2.1 - Summary of interview program
Interviewees Total contacted Completed
Declined/no
answer
Standard bodies 5 5 0
MS competent authorities 33 284 5
WELMEC working groups and secretariat 8 8 0
SME representatives 1 1 1
Consumer associations 1 0 1
Trade associations and
manufacturers/importers/users
- M-001 water meters 15 5 10
- M-002 gas meters 9 7 3
- M-003 electricity meters 9 4 5
- M-004 heat meters 7 5 2
- M-005 other liquid non-water 17 4 13
- M-005 petrol pumps 14 7 7
- M-006 AWI 17 4 13
- M-007 taximeter 9 4 5
- M-008 tapes/dipsticks 11 3 8
- M-008 cap serving measures 6 3 3
- M-009 dimensional measure 11 4 7
- M-010 exhaust gas analyser 17 2 15
Total 190 91 99
Notified bodies survey
4 Two cases are based on written responses provided by DG Enterprise.
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Separately to the interview programme, an electronic survey of the 140 accredited notified bodies was
organised. The questionnaire (see Appendix D) was available in five languages
Thirty nine (39) responses of Notified Bodies had been received by 30 April representing, according to
our experience, a good response rate for this type of survey (28%). It provides an extensive coverage of
countries, MIs sectors and activity levels. The results of the survey are presented in Section 5.1.
SME survey
An additional source of input was the SME test panel survey organised by the Commission. The
responses of 286 SMEs were forwarded to CSES and provided additional input in relation to the key
evaluation of the impact of the Directive on SMEs. The results of the survey are presented in Section 5.2.
2.3 Market data collection
A key task of the study concerned the estimation of the market size, employment size, number of firms
and level of trade of the MIs covered by the Directive and of other instruments that could also be
included.
CSES used a number of sources to bring together data concerning the size of the market of MIs:
• Market research reports on specific categories of MIs providing data on the global and European
and national market size, market trends and main manufacturers by type of instrument. CSES
purchased the Multi Utility Meter Report Ed 7 2009 of ABS Research and the European Garage
Equipment market study of Leo Impact Consulting concerning Exhaust Gas Analysers.
• Data from trade associations and from manufacturers related to market size of instruments
manufactured or traded by the companies they represent. We asked trade associations and
manufacturers about the availability of data on the respective MIs covered. A few of them provided
exact data or estimates of the size of the market. The interviews also provided information on
average life cycle and average price of MIs. This data was used where official estimates were not
available.
• Data from legal metrology authorities (including the online database on MID certifications) and
concerning the number of national and EC type approvals, verifications and re-verifications and
inspections covering specific measuring instruments both covered and not covered by the MID5.
• European databases on production, sales and trade volumes and values. EUROSTAT maintains data
of production volumes and values (PRODCOM Annual data for period 1995-2008)6 and trade
volumes and values (External and Internal trade statistics7 for period 1995-2008) for the EU27 at an
5 For example CECOD provided data on the size of the market of industrial measuring systems and retail measuring
systems for gasoline (MI-005) that were included in Annex 4 of the proposal of WELMEC working group 10.
Similarly, the report of the Ministry of Economics of Latvia provides data on some of the MIs produced or
circulated in the national market following the requirements of the Directive. 6 Eurostat (2009), PRODCOM database,
http://epp.eurostat.ec.europa.eu/portal/page/portal/prodcom/data/tables_excel 7 Eurostat (2009), External and internal trade database,
http://epp.eurostat.ec.europa.eu/portal/page/portal/external_trade/introduction
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eight-digit product classification level that generally fits with the product sectors of the MID. During
the first phase of the study we developed a correspondence table of the different classification
codes used by the statistical databases and the 12 sectors of MIs (see Appendix D).
Priority was given to data provided by market research reports as the most reliable source of
information. Data from trade associations was also given priority when available. The remaining two
sources were used as alternatives with rather reduced reliability. Verification data was provided from
only some Member States and were not always consistent in the coverage of the different sectors.
Furthermore, in many cases verifications were based on samples and it was not always possible to
derive proper estimates. In the case of EUROSTAT data the correspondence between sectors and
product codes was not always very clear and there were many overlapping areas. Furthermore, the
derived unit costs were in some cases very different from what industry or desk research would
indicate. In all cases, there was an effort to cross-check with other sources of information. An important
complication is that in a number of categories of MIs covered by the Directive the production volumes
and values made available did not concern MIs used only for trade purposes. Particularly, under MI-008
(material measures) and MI-009 (Dimensional measuring instruments) large part of the market concerns
household uses or other non-trade-related activities outside the scope of the MID. It was not always
possible to differentiate between the two uses and most trade associations did not have relevant data.
As a result, the data presented for some categories provide estimates of the total size of the sector and
some upper limits of the MID related market.
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In this section, we present the results of the market data analysis. Approximate figures are provided for
the total size of the market in terms of annual turnover and number of units sold, number of
manufacturers and, wherever available, employment size. For some categories of measuring instruments
data concerning imports and exports are also provided.
3.1 Utility meters - general
Data for the market of utility meters (MI-001-MI-004) are extracted from the ABS market research
report. According to the report, the majority of companies in the sector are active in more than one of
the four categories of measuring instruments. There is a strong concentration of the four sectors with a
few large multinational manufacturers dominating most of the markets. In a few Member States
domestic suppliers dominant are important. The total utility meter industry occupies, according to the
ABS report, 30,000 to 40,000 employees. The following table summarises the position of the most
important participants in the market.
Company Employees Turnover
(million €) Water Gas Electricity Heat
Ranking (in terms of
market share in the
utility sector)
Elster (DE) 7,500 1,980 x x x 1
Itron (USA) 8,500 1,700 x x x x 2
Landis+Gyr (CH) 5,070 1,083 x x x x 3
Sensus (USA) 4,000 800 x x x x 4
Diehl (DE) 12,0008 2,000
8 x x 5
Kamstrup (DK) 650 126 x
Iskra (CZ) n.a n.a. x
Apator (PL) 1,700 90 x x
ZPA (CZ) n.a n.a x
AEM (RO) 1,400 n.a x
Maddalena (IT) n.a n.a x
Zenner (DE) n.a n.a x x
Bruno Janz (PT) n.a n.a x x
Watteau (FR) n.a n.a x
Metron (PL) n.a n.a x x
Source: ABS research report
3.2 MI-001 - Water meters
According to the ABS report, in 2008 Europe had an installed base of 157 million water meters, with
annual demand at around 18 million units at a total value of €447 million. Residential water meters
account for €290million (11.5 million units) while commercial and industry the remaining €157 million
but only 0.7 million units as they tend to be priced much higher. Europe imports around 10% of the total
demand in meters, mainly from China while European manufacturers export around the same amount
to the CIS, North America and the Middle East.
8 Data for Diehl concern all sectors the company is active and not only utility meters.
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AQUA, the trade association of water and heat meters has 12 members, all of which are manufacturers
of significant size. The main suppliers of water meters in Europe are Elster, Itron and Sensus that
together occupy around 20,000 employees and control around 55% of the total share of the market. A
second tier of water measures manufacturing companies includes Diehl and Zenner followed by a
number of smaller companies that are mainly present in their respective national markets. These
include Bruno Janz (PT), Watteau (FR), Poworgaz and Metron (Poland) and Maddalena (IT).
3.3 MI-002 - Gas Meters and volume conversion devices
According to the ABS report, Europe has an installed gas meter customer base of around 112 million gas
meters. Annual demand for gas meters is expected to rise from EUR 357 million (6.9 million units) in
2008 to EUR 411 million (7.6 million units) in 2012. Europe is a net exporter of gas meters; in 2007, it
exported over 4.6 million units while only importing less than 450,000 units, mainly from China.
The gas meter market is the most concentrated of the utility meter markets. Two companies, Itron and
Elster are by far the largest producers in Europe representing more than 70% of the market in Germany
(Elster has a 45% share of the market, and Itron 35%) but even up to 94% in Poland. Together they
occupy over 16,000 employees9. Other large size multinational manufacturers (Landis+Gyr and Sensus)
are also present on the European market but they have far smaller market shares, even from domestic
manufacturers like Apator (PL). Romania and Switzerland stand out as two of the only countries where
the two companies do not have a dominant share thanks to AEM Timisoara in Romania and GWF in
Switzerland. In total, there are around 17 companies in Europe that, put together, occupy around 30,000
employees.
3.4 MI-003 - Electricity Meters
There were approximately 302 million electricity meters in Europe in 2008. Annual demand is 14 million
units (€610 million). The level of production of electricity meters exceeds the total demand by around 4
million units, but the region still imports over 7.5 million units, mainly from European manufacturer’s
production facilities in China. Between 2008 and 2012, European demand is expected to grow by 15.8%
in units and 25.8% in value.
The dichotomy between volume and value increase is due to the decisions by a number of governments
to invest in advanced metering systems. As a result, demand for electromechanical and basic electronic
meters should fall from 52% of the total market in 2008 to 14% in 2012, while demand for AMI
(Advanced Measuring Infrastructure) Meters should grow from 20% to 79% over the same period.
The largest manufacturers in Europe are Landis+Gyr (30% of the market in value) and Itron (17%) and
are the dominant participants in most Member States’ markets. Elster has a share of 1.6%. Other
notable participants include the Egyptian El Sewedy through its purchase of Iskra in 2006, and other
national or regional companies such as Apator (Poland), ZPA (45% of the Czech market) and AEM
Timisoara (85% of the Romanian market). Finally, a number of manufacturers provide meters in one
country exclusively, such as ENEL for Italy or Sagem in France. In total, there are around 25
manufacturers in Europe that occupy approximately 32,000 employees.
9 This number refers to the total number of employees and not only to the sector.
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3.5 MI-004 - Heat meters
The installed base of heat meters in Europe in 2008 stood at around 10 million units, with annual
demand at around 800,000 units (value of €290 million). Europe produces most of its demand in heat
meters and exports are relatively few, as there is no large market outside Europe requiring meters of the
quality and technology built in Europe. The market for heat meters is relatively diverse in the EU.
Germany, Poland, Sweden, Denmark and Finland represent over 70% of the European market. During
the last few years the European market for heaters has been rather saturated but experts consider that
a switch from evaporator meters to more technologically advanced ones, especially those with remote
reading capabilities, will boost future demand.
The European market is dominated by Kamstrup (around 47% of the 10 million installed meters), a
company specialising in this category and with around 650 employees. Other companies with important
presence in the sector are the large-scale manufacturers Diehl (22% of the sector), Landis+Gyr (12%) and
Itron (6 %). In total it is estimated around 10 companies are active in the sector in Europe occupying
approximately 18,000 employees10
.
3.6 MI-005 - Measuring systems for liquids other then water
MI-005a – Fuel dispensers
According to the European Committee of Manufacturers of Petrol Measuring Systems (CECOD) there are
currently around 120,000 petrol stations in the EU27 with approximately 300,000 petrol dispensers
installed. CECOD suggests that petrol dispensers have an annual life cycle of 12 years and, based on this
assumption, estimates that the size of the European market on an annual base is around 25,000 systems
with a total value of around €200million based on a unit price of around €8,000. CECOD did not provide
data on imports/exports. Based on PRODCOM data concerning petrol pumps11
the level of imports from
outside Europe does not exceed 3% of the total market size.
In terms of the manufacturing base, CECOD has a total of 21 members of which 10 are producers of fuel
dispensers for petrol stations. Overall no more than 20 companies are active in this sector. There are a
few large size participants including Gilbarco, Tokheim and Dresser Wayne with a presence across
Europe that represent more than 60% of the market. Most other manufacturers are present in only a
few Member States. It is estimated that the main companies in the sector employ around 10,000
employees without referring to importers or local distributors. Furthermore, based on PRODCOM data
on fuel pumps12
around 16% of the production of Europe is exported outside EU while imports represent
no more than 3% of the market.
10 This number refers to the total number of employees of the companies and not only those in the sector. The
actual number is likely to be lower due to the smaller number of units sold in Europe compared to other utility
meters. 11
One dispenser may have more than one pump. 12
Number of dispenser and pumps do not coincide as depending on the arrangement one dispenser may have
more than one pumps for different fuels.
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MI-005b – Other liquid dispensing systems
According to CECOD there are around 35,000 existing installed measuring systems on tanker trucks.13
With an average life cycle for instruments of around 10-12 years, it is estimated that around 3,200 new
MIs enter the market on an annual basis with a total value of around €20million, giving a price per unit
of €6000. Concerning MIs in fixed installations14
CECOD refers to a total installed base of 25,000
instruments across the EU and an annual market of around 3,000 new MIs entering the EU market. Their
reported market value is close to €52.5 million.
However, as in the case of fuel dispensers, the data from national verification from a few countries
indicate that CECOD data may underestimate the total size of the market.
CECOD could not provide data concerning the number of manufacturers and employees occupied in the
sector. Almost all manufacturers belong to the SME category with less than 250 employees, most with
less than 100. There are also a number of very small local companies across Europe that assemble
components that do not have MID certified instruments that are mainly used for non trade purposes.
The estimated number of employees occupied in the sector is around 4,000-6,000.
3.7 MI-006 – Automatic Weighing Instruments
The data provided by the European Committee of Weighing Instruments Manufacturers (CECIP) for the
eight countries15
that are represented by the association indicate a total value of production of AWI in
2008 close to 23,000 units. Around 17,000 were used for legal metrology purposes falling under the
MID. The value of these instruments in 2008 was around €440 million. That represent 15% of the total
production of automatic and non-automatic weighing instruments. According to CECIP, its members
represent 75-80% of the total production in Europe so it can be estimated that the total number of AWI
is around 28,000 and the MID related approximately 21,000 with a total value of €550million, giving a
price per unit of €2750. Based on an average life cycle of approximately 10 years the installed base
should be close to 210,000 instruments.
Concerning the share of different categories of AWI, the data provided by CECIP indicate that
catchweighers represent 42% of the total production (8,750), filling instruments 36% (8,000),
discontinuous and continuous totalisers 19% (4,000) and rail weighbridges 4%(900). The above numbers
are close to that of PRODCOM database which also includes instruments not used for legal metrology.
They indicate a total annual market size of around 15,000 catchweighers and checkweighers, 14,000
filling instruments, 7,000 continuous and discontinuous totalisers and, based on the 4% estimate of
CECIP, 1500 weighbridges.
Concerning the size of the sector, CECIP data suggest the presence of 700 companies active in the
production of automatic and non-automatic weighing instruments. Among those, approximately 100
companies are present in the market with their own original products such as balances and scales for
different applications and in many market segments among which 30-50 produce AWI. In total, the
weighing industry employs around 50.000 people 50% of which are employed by SMEs. CECIP reports
13 System on (un)loading ships, rail, road tankers and systems for refueling aircraft.
14 Systems for cryogenic liquids, milk, liquid and liquefied gases.
15 CZ,UK,DE,FR,NL,PL,SK,IT
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also the presence of 4000 - 5000 very small or micro companies (1-3 employees) that are service
providers, but also occasionally assemble scales in limited editions. Based on the 15% of the AWI sector
we can estimate that the sector occupies 7,500-10,000 employees in Europe.
3.8 MI-007- Taximeters
Concrete data based on market analysis is not available for the taximeter market in Europe. The figures
provided are estimates based on data concerning the number of verifications from the certifying
authorities in some countries and additional information provided by manufacturers.
The data from verifications in some countries (DE, FI, NL, LV, and SLO) and the discussions with
manufacturers indicate an average of one taxi per 1000 inhabitants across Europe (range between 500
in FI to 2300 in NL). Assuming one taximeter per taxi and a total European population of 500 million we
estimate a stock of around 500,000 taximeters in the market. The estimated life cycle of taximeters is
approximately 10 years indicating 50,000 taximeters sold annually in Europe. According to the
information collected, the price of taximeter varies between €200 and €400 in Central and Eastern
Europe countries and close to €800 in Nordic countries. Thus, the value of the taximeter market should
be around €25-40 million.
Member States provided some information on number of companies in the sector based on the number
of MID certificates, and we also carried out interviews. The results indicate the presence of a small
number of manufacturers (still almost all classified as SMEs) in multiple countries – either directly or
through local distributors (and exports outside Europe). The main manufacturers identified in multiple
countries include Digitax (IT), Hale Electronics (AU), Interfacom (ES), Kienzle Argo (DE), ATA (FR).
Together they do not employ more than 500 employees in this area, excluding the various local
distributers. These companies do not specialise in taximeters but may also cover a wide range of
electronic systems related to the transportation and logistics sectors. In addition, in a number of EU
countries there are very small size companies (<25 employees) that – with few exceptions - focus
exclusively on the respective domestic or local markets. In the case of the UK, according to one
interview source, there up to 35 such enterprise of 1-2 employees, with almost none of them selling
MID certified taximeters. More commonly, there are one or two local companies (specialised or not)
whose taximeters compete with those of the domestic manufacturers16
. In total, there are around 50-60
companies in Europe employing less than 1000 employees in total. However, one should also add the
distributors, installers and service providers in each country but it was difficult to obtain any meaningful
estimate.
3.9 MI-008 – Material measures
Material measures of length
Data for the material measures of length have been very limited. PRODCOM and number of national
verifications from a small number of countries were the only sources available. Measuring rods and
tapes coincide with two codes of PRODCOM database (Measuring rods and tapes and divided scales-
Product code 28293975 and Hand held instruments for measuring length-Product code 28293979).
16 We identified such companies in Czech Republic, Finland, Sweden, Greece, Poland, Latvia.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Market data analysis
3
15
According to the PRODCOM data17
the total number of units sold in Europe in 2008 was close to 130
million with an estimated value of €290million, giving a price per unit of €2.50. On the basis of a 10 year
life cycle the total installed base is estimated at around 1.3billion units. However, only a small share of
this total volume is used for trade purposes but the Hand Tools Association stated that they do not have
figures on the number of tools subject to metrological control and the interviews did not provide any
further guidance.
In terms of companies, the hand tools association has a total of 22 members under the subgroup
measuring instruments – most of which produce measuring tapes and rods. In addition, the review of
certificates database indicates 15 more companies with at least one MID certificate. Altogether, these
companies occupy in total close to 14,000 employees. Information on SMEs present in the domestic
markets is not available.
Capacity serving measures
Data from European Glass Containers Association (FEVE) indicate that the total volume (in tonnes) of the
production of glass-made containers sold in 2008 was 22.4million tonnes18
of which 1.4million tonnes
concerned tableware (glasses, jars but also bowls etc.). As a very rough estimate this represents 3.5
billion glasses19
. However only a small proportion of these glasses and jars are sold for trading purposes
and are MID-certified. FEVE did not have precise data on the share of production directed towards
containers for trade purposes (thus falling under the MID) in 2008. Inputs from its members suggest that
the share of capacity serving measures that are CE-marked does not exceed 5% of the total production.
This indicates a total volume of 150-200 million capacity serving measures sold across Europe. Although
an installed base may not be a meaningful concept in the case of capacity serving measures, based on an
average lifecycle of 0.7 years the installed base is 250 million units.
In terms of active companies, the overall tableware glass sub-sector (including most of the companies’
manufacturing capacity serving measures) is widely distributed across the EU. One study20
of the sector
indicated that there are 50-60 large installations spread out across the EU along with around 200 small
and medium size firms occupying 20,000 employees. France, Germany, Italy and Austria account for 60%
of EU production with the remainder coming from 16-18 other Member States (EC (2008)). Production
in the new Member States takes mainly in Poland and the Czech Republic, which each produce 5-5½% of
EU output while Slovakia accounts for 3% of EU output. An important part of the domestic market is also
served by imports from China (either Chinese companies or European companies with facilities in China)
and Turkey21
.
17 The total size of the market for each code is calculated based on the following formula:
Market size for EU27 = Total value(volume) of products sold in EU27 (PRODCOM Data) – Value(volume) of Exports
(TRADE Data) + Value(volume) of Imports (TRADE Data) 18
Data include Turkey. 19
Based on glass weight of 0.4kg according to FEVE. 20
http://www.allbusiness.com/nonmetallic-mineral/glass-glass-manufacturing/545690-1.html 21
According to PRODCOM imports to EU27 represent around 24% of the total value of drinking glasses sold.
However the correspondence with the data presence is not very clear. Exports from EU represent around 45% of
the number of glasses produced.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Market data analysis
3
16
We need to note that the above data does not cover the capacity serving measures made from plastic
(mainly polycarbonate and polypropylene) which can be significantly cheaper (5-10 times) and are
increasingly used in bars and pubs. We did not find any data on this specific segment of the market to
allow for proper estimates.
3.10 MI-009 – Dimensional measuring instruments
Data concerning dimensional measuring instruments is very limited. Only two countries provided data
on the number of verifications and re-verifications and such data appear to be rather inconsistent. The
only other source is the PRODCOM database which covers electronic instruments, appliances and
machines for measuring or checking geometrical quantities (Product code 26516650) and Optical
instruments, appliances and machines for measuring or checking (Product code 26516630). The data for
2008 indicate a total volume sold in Europe at a level of 6million units for a value of €1.4billion. With an
estimated 10 year life cycle the installed base should be around 60million units. However, it is unclear
what share of the market represents instruments used for trade purposes. By extrapolating from the
German data (700,000 instruments) one can estimate that the installed base of MID related dimensional
measuring instruments is no more than 3-4 million units (5% of the total).
The only source for the number of active companies is the certificates database indicating the presence
of 20 companies occupying 7000 employers22
. Small size firms with no MID certified products are not
included in these estimates. Distributors and importers are not included in these figures.
3.11 MI-010 – Exhaust gas analysers
According to the Gas analysers report23
there were 17,050 units sold in 11 EU members in 2008 that
include Germany, France, Italy, Spain, Benelux, the three Scandinavian countries (DK, SE, NO) and the
UK. For the EU27 we can estimate around 22,000 units sold around the EU (based on 0.5 cars/capita in
EU15 and 0.3 cars/capita for new Member States)24
. Their life cycle is 8 to 10 years which indicates an
installed base of 250,000 units. Based on the same source the size of the total EU27 market is estimated
at around €90million. The above numbers are more or less in agreement with that derived from the
limited data on verification of gas analysers that indicate an average of 1000 analysers per car in Europe
(250million cars) that corresponds to an installed base of 250,000 analysers.
Based on the gas analysers report the production volume of the EU7 in 2008 was around 28,000 units
which indicates that 40% is directed towards exports. Production in Germany, Italy and the UK represent
88% of the total volume.
In terms of manufacturers, the European Garage Equipment Association refers to a total of 650
companies in the sector as a whole, occupying around 40,000 employees. The market report refers to 60
companies present in the EU27 (including companies from other European countries) occupying around
17,500 employees25
. Based on another market report26
the European diagnostic equipment market is
22 Based on the information collected from the companies websites.
23 European Garage Equipment market study 2008 – Leo-Impact Consulting GMBH
24 http://europa.eu/rapid/pressReleasesAction.do?reference=STAT/06/125
25 This is the number of the employees of the companies that may be present in other sub-sectors of the garage
equipment industry.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Market data analysis
3
17
dominated by 8-10 suppliers that include Robert Bosch-Automotive Aftermarket (DE), Gutmann
Messtechnik (DE), Texa Spa (IT), SPX-Technotest (US), AVL DiTEST (AT), Omitec (UK) and Snap-on (USA),
Brain Bee (IT). The combined market shares of these suppliers accounts for around 60% of the overall
European sales.
3.12 Summary of market data
Table 3.1 below summarizes the data estimates for each of the measuring instruments sectors and
subsectors examined. In total, we estimate that the MID applies to around 345 million units of MIs sold
annually in the European market with a total value of €3.25 billion. The greatest share in terms of value
concerns electricity meters (18.8%) and automatic weighing instruments (16.9%). In total, the utility
meters represent 50% of the total value of the MID instruments. On the other side, taximeters represent
less than 1% in terms of total market size.
In terms of the size of the sectors, around 900 companies are involved in the production of the 10
different categories of legal metrology instruments based on the information collected although this
number does not include distributors or importers. In terms of employees, the data available indicate a
total of 175,000-205,000 occupied in companies that manufacture MIs27
. This number does not include
distributors or importers of instruments but it may also include some double counting in the case of
utility meter companies that are active in more than one sectors.
Finally, the available data on share of imports and exports indicate a variation in terms of the
dependence from non-EU markets. In the case of the lowest technology sectors of MI-008 and MI-009,
reach up to 50% of the market, while in the case electricity meters sector close to 65%. In many cases
these are European companies with an established manufacturing base outside the EU. In most other
categories, the level of imports does not exceed 20% of the total market. We should note that data for
some categories of MIs are based solely on the PRODCOM database and should be treated with caution.
26 http://www.researchandmarkets.com/reports/603619/strategic_analysis_of_the_european_diagnostic
27 In the utilities sectors, most of the large scale companies are active in more than one categories. By adding the
numbers for each category there is a possible double counting.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Se
ctio
n
Ma
rke
t d
ata
an
aly
sis
3
18
T
ab
le 3
.1 –
Su
mm
ary
ta
ble
wit
h E
U2
7 m
ark
et
da
ta f
or
me
asu
rin
g i
nst
rum
en
ts2
8
Inst
all
ed
ba
se
–n
o.
of
un
its
(00
0s)
Ma
rke
t si
ze –
nu
mb
er
of
ite
ms
(00
0s)
Ma
rke
t si
ze-
va
lue
(m
illi
on
€s)
Sh
are
in
tota
l M
Is
ma
rke
t
Imp
ort
s (%
of
ma
rke
t
va
lue
)
Ex
po
rts
(% o
f
va
lue
of
pro
du
ctio
n)
No
. o
f fi
rms
in E
uro
pe
Em
plo
ye
es
occ
up
ied
MI-
00
1:
Wa
ter
Me
ters
1
57
,00
0
18
,00
0
45
0
13
.8%
1
3%
1
4%
2
0-3
0
25
,00
0
MI-
00
2:
Ga
s M
ete
rs &
Co
nv
ers
ion
De
vic
es
11
2,0
00
6
,90
0
41
0
12
.6%
7
%
44
%
15
-20
3
0,0
00
MI-
00
3:
Act
ive
Ele
ctri
city
En
erg
y
Me
ters
30
2,0
00
1
4,0
00
6
10
1
8.8
%
60
%
65
%
25
3
2,0
00
MI-
00
4:
He
at
Me
ters
1
0,0
00
8
00
2
90
8
.9%
2
0%
3
2%
1
0
18
,00
0
MI-
00
5:
Me
asu
rin
g
Sy
ste
ms
for
Liq
uid
s
oth
er
tha
n W
ate
r
36
0
31
.2
24
0
7.4
%
Fu
el
dis
pe
nse
rs
30
0
25
2
00
6
.2%
3
%2
9
16
%2
9
20
1
0,0
00
Me
asu
rin
g s
yst
em
s o
n
tan
k t
ruck
s 3
5
3.2
2
0
0.6
%
n.d
n
.d.
30
-40
4
,00
0-6
,00
0
Me
asu
rin
g s
yst
em
s o
n
fixe
d i
nst
all
ati
on
s 2
5
3.0
2
0
0.6
%
MI-
00
6:
Au
tom
ati
c
We
igh
ing
In
str.
2
10
2
1
55
0
16
.9%
3
50
2
5,0
00
Au
tom
ati
c
catc
hw
eig
he
rs a
nd
che
ckw
eig
he
rs
15
0
9
3.5
%3
2
19
%3
2
Au
tom
ati
c g
rav
ime
tric
fill
ing
in
stru
me
nts
1
40
8
1
6%
32
42
%3
2
Dis
con
tin
uo
us
an
d
70
4
n
.d.
n.d
.
28 D
ata
fo
r M
I-0
01
, M
I-0
02
, M
I-0
03
an
d M
I-0
04
in
clu
de
als
o N
orw
ay
, S
wit
zerl
an
d a
nd
Tu
rke
y.
2
9 B
ase
d o
n E
uro
sta
t P
RO
DC
OM
da
ta f
or
pe
tro
l p
um
ps.
On
e f
ue
l d
isp
en
ser
typ
ica
lly
ha
s m
ore
th
an
on
e p
um
p.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Se
ctio
n
Ma
rke
t d
ata
an
aly
sis
3
19
Inst
all
ed
ba
se
–n
o.
of
un
its
(00
0s)
Ma
rke
t si
ze –
nu
mb
er
of
ite
ms
(00
0s)
Ma
rke
t si
ze-
va
lue
(m
illi
on
€s)
Sh
are
in
tota
l M
Is
ma
rke
t
Imp
ort
s (%
of
ma
rke
t
va
lue
)
Ex
po
rts
(% o
f
va
lue
of
pro
du
ctio
n)
No
. o
f fi
rms
in E
uro
pe
Em
plo
ye
es
occ
up
ied
dis
con
tin
uo
us
to
tali
sers
Ra
il-w
eig
hb
rid
ge
s 1
5
0.9
MI-
00
7:
Ta
xim
ete
rs
50
0
50
2
5-4
0
1.0
%
n.d
. n
.d.
50
-60
1
,00
0
MI-
00
8:
Ma
teri
al
Me
asu
res
3
05
,00
0
44
0-4
90
1
4.3
%
3
4,0
00
Ma
teri
al
me
asu
res
of
len
gth
30
1,3
00
,00
03
0
13
0,0
00
30
29
03
1
8.9
%3
1
50
%3
2
29
%3
2
40
33
14
,00
03
1
Ca
pa
city
se
rvin
g
me
asu
res3
4
25
0,0
00
1
75
,00
0
15
0-2
00
5
.4%
35
25
%3
4
45
%3
4
25
0
20
,00
0
MI-
00
9:D
ime
nsi
on
al
Me
asu
rin
g I
nst
r.
3,0
00
-4,0
00
3
00
-40
0
70
-80
2
.3%
5
5%
34
65
%3
4
20
-30
35
7,0
00
MI-
01
0:
Ex
ha
ust
Ga
s
An
aly
sers
2
50
-35
0
25
-35
1
30
4
.0%
n
.d.
n.d
. 5
0-6
0
17
,50
0
To
tal
3
45
,00
0
3,2
15
-3,2
90
1
00
%
22
-27
%
25
-30
%
88
0-9
40
1
75
,00
0-
20
5,0
00
30 D
ata
re
fer
to a
ll m
ate
ria
l m
ea
sure
s o
f le
ng
th i
n t
he
ma
rke
t. N
ot
on
ly M
ID c
ert
ifie
d.
3
1 G
ive
n t
ha
t th
ese
fig
ure
s in
clu
de
als
o n
on
MID
ce
rtif
ied
in
stru
me
nts
th
is n
um
be
r sh
ou
ld b
e s
ma
lle
r.
32 C
on
cern
s o
nly
me
asu
rin
g r
od
s a
nd
ta
pe
s.
33 D
oe
s n
ot
incl
ud
e v
ery
sm
all
fir
ms
wh
ich
, u
sua
lly
, d
o n
ot
pro
du
ce M
ID p
rod
uct
s.
34 D
ata
re
pre
sen
t u
pp
er
est
ima
tes
35 I
ncl
ud
es
on
ly c
om
pa
nie
s th
at
ho
ld M
ID c
ert
ific
ate
s.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Analysis by sector
4
20
In this section we present the findings of the analysis for each of the categories of measuring instruments
based on the data collected focusing on overall experience and specific problematic areas. Direct
reference to the empirical evidence and the information collected from the different sources is made
where applicable. A detailed analysis with the findings for each category of measuring instruments
concerning all evaluation questions – including examples or relevant data were available - is presented in
a tabular format in Appendix E.
4.1 MI-001 – Water meters
The findings of the fieldwork suggest that the sector has benefited from the use of a single certification
towards the development of a more coherent single market.
With the exception of two countries for residential use and four for industrial, optionality has not been
used in the case of water meters. In the countries used, the authorities referred to either absence from
the market (concerning industrial meters) or no perceived policy need. The findings of the study indicate
that there are no issues or problems linked to optionality. More generally, in relation to the level of
consumer protection, the industry (represented by AQUA) proposes that the actual users of meters - the
water distribution companies - have a vested interest in using reliable water meters. These companies
have the mechanisms to test the quality of the meters and as a result, consumer protection should not
be considered an issue.
With regards to the impact of the MID in innovation, the industry does not see the Directive as
hampering innovation as a result of essential requirements. In most respects the provisions of the MID
are similar to those under the older Directive 75/33/EEC. The only issue mentioned concerns the current
levels of operating conditions defined in the Directive that is considered inappropriate36
. A more serious
issue concerns the coverage of smart meters by the MID. According to some industry representatives
and competent authorities, they are the most important category of meters. While nearly half of
competent authorities suggest that smart meters should be covered by more rules in the MID there is
no consensus. A number of forums and consultations are still ongoing that are expected to provide
proposals in relation to the future of smart meters.
The industry does not consider that the MID has created additional administrative burden. The MID
did not radically change the previous regime but adapted and harmonised pre-existing rules and
procedures.
Another important aspect of the MID in the case of MI-001 is the increased participation of the industry
– represented by AQUA - in WELMEC’s working groups. It has increased the opportunity to raise issues
and participate and provide input in relation to all critical issues that concern the application of the MID.
Finally, given the dominance of few large firms in the sector, there is no significant impact of the MID
on SMEs. The absence of important problems from those SMEs active in the sector – manufacturers,
importers and distributors – is also supported by the results of the SME survey that indicated no
problems concerning either the conformity procedures or any significant barriers to trade.
36 For the moment a ratio of 10 between the defined permanent flowrate and the minimum flowrate allowed. The
industry considers that a ratio of at least 40 is appropriate.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Analysis by sector
4
21
4.2 MI-002 - Gas Meters
The findings of the study suggest that MID has been well received and represents an improvement on
the previous regime. The main strength of the Directive has been the improvement of free trade and
the development of a truly common market. Particularly positive, as stated by both industry and
governments, is the opportunity for manufacturers to participate in public procurement contracts
throughout Europe without the need for national certification, increasing competition and, possibly,
lowering prices.
Regarding technological improvements, the MID is generally seen as technologically neutral and does
not hamper technological innovation. There are suggestions that the introduction of the Directive has
increased standards in some countries to the benefit of consumers. However, there are fears expressed
new developments in gas metering field may require rule development in the MID to cover the display
of energy or monetary values and the use smart meters. Such equipment, that will fit to existing
instruments are expected to increase in future in response to energy efficiency regulations. However,
while many Member States support the eventual inclusion of smart meters in the MID, until there is
more technological stability the industry proposes that no change should take place at this moment.
A number of other issues were also identified. One issue is the lack of a common definition for ‘light’
and ‘heavy’ industry which can lead to problems in deciding which types of meters fall under the
Directive and could even cause a trade barrier. As reported, the threshold in Germany is over 9,000
times that of the Netherlands. Another issue is the level of market surveillance that is still seen as too
limited despite recent improvement. However, there was no evidence provided of unfair competition or
of consumer protection issues, but of course the market (both in terms of manufacturers and users) is
highly concentrated. Finally, the quality of notified bodies varies. Firms reported a problem with
different interpretations they give of WELMEC guidance documents.
Finally, both trade associations have been actively involved and made a positive assessment to the
working group meetings of MID and of WELMEC.
4.3 MI-003 - Electricity Meters
The findings of the study suggest an overall positive experience from the implementation of the MID for
electricity meters. Overall the introduction of the MID is considered a positive development by the
electricity meter industry. MID has helped simplify the relevant legal framework and makes a positive
assessment of the use of a single certificate for accessing the EU market.
Having said that, there are a few issues or problems that hamper the completion of the single market.
Some functionalities of electricity meters are limited by national regulation and require national
certification. This results in a situation where old and new regimes run in parallel. Furthermore, as in the
case of gas meters, the freedom provided by the MID to Member States in determining the different
classes of meters (residential, commercial / light industrial) is also seen as creating obstacles in the
smooth operation of the market.
The industry was also critical of the fact that some harmonised EU standards used in the MID are in
conflict with some of the standards of the International Electrotechnical Commission, as they create
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Analysis by sector
4
22
confusion and complications for firms37
. It was suggested to us their view of that WELMEC guidance
documents is not always clear and supportive.
In relation to the impact of the MID on technological innovation, the main issue raised concerned the
need for the eventual development of rules for smart meters in the Directive. The fieldwork has shown
that some manufacturers consider that WELMEC’s guidance documents are unclear although this is not
the view of the industry as a whole.
Optionality is not an issue for the sector as only one country (Malta) has elected not to regulate the
market of electricity meters.
Interviews with the industry also indicate that the MID has not led to an overall decrease of the
administrative burden as a result of the presence of national regulation for some functionalities. Most
suggested that any decrease in the administrative burden achieved in relation to light industrial and
commercial meters has been cancelled out by the increase in procedures for residential meters.
In contrast to the other utility meter manufacturers, the association representing manufacturers of
electricity meters – Eurelectric – were rather negative concerning their representation and role in the
decision making procedures. Despite their participation in most of the relevant working groups, they
consider that the absence of voting rights for industry limits their opportunity to influence decisions.
4.4 MI-004 – Heat Meters
The findings of the study suggest that the heat meter sector recognise a positive contribution of the
MID in the simplification of the market. In that respect, some manufacturers suggested that the
introduction of the MID might help the development of heat metering in the countries where it is
currently not present.
Concerning optionality, five countries have opted out from the MID and for residential heat meters and
six for commercial and light industrial meters. The countries that opted out of the MID for heat meters
did so because of the lack of heat meters in their national markets. Although initially industry considered
that this was a risk for the creation of a truly harmonised market, there has been no evidence so far of a
two-tier market developing as a result of optionality.
In relation to the representation in the MID processes, the industry representatives were particularly
positive about the presence and contribution of WELMEC working groups that operate as a forum for
the exchange of experience and points of views. The documents drafted by WELMEC are also seen as
crucial to the success of the MID helping towards the harmonisation of views within the framework of
the Directive.
Furthermore, in contrast to other sectors, the view of the industry is that WELMEC guidance documents
play a positive role in the definition of a common interpretation of the MID and have also helped in the
37 According to the report on the MID provided by Eurelectric “the definition of ‘Rated Operating conditions’ is not
as satisfactory as that in IEC standards and ‘Critical change value’ is an arcane metrology concept also not well
defined’.
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23
development of a common interpretation by Notified Bodies which, in turn, has contributed to a
decrease of the administrative burden to manufacturers.
A more problematic aspect – consistent with other sectors- is the rather poor level of market
surveillance. However, it is not seen as a critical problem as manufacturers usually sell their meters to
trusted customers. Still, the introduction of the NLF is expected to have a positive contribution although
the extent to which this will improve the situation remains unclear.
4.5 MI-005 Measuring systems for liquids other then water
MI-005a – Fuel dispensers
The findings of the fieldwork suggest that while the sector has benefited from the use of a single
certification that helped towards the development of a single market, a number of issues and obstacles
pose rather important problems to manufacturers and to CAs. Manufacturers indicate a relatively
problematic overall experience from the implementation of the Directive up to this point.
The first important issue in relation to the efficient operation of the single market concerns the
additional requirements that are posed by some authorities and inspection bodies of Member States in
relation to additional requirements and checks concerning CE+M marking or the use of the necessary
seals. According to the industry representatives (CECOD) such requirements concern the use of MIs but
also affect their entry and circulation in the market. We must note though that such claims are disputed
by the relevant authorities because only limited evidence has been provided.
The second issue is linked directly to the provisions of the Directive and what the industry considers a
problem with the MID. The problem is the issue of combining “old” non-MID certified points of sales38
with new MID-certified fuel dispensers in petrol stations (and the reverse). It is seen as a major
limitation for the development of the market in a number of countries. CECOD and the National Petrol
Stations Association reported that over 80% of the UK market is still operating on the basis of non-MID
certified dispensers39
. It is proposed that the current arrangement is particularly an issue for small firms
that produce only part of the whole system. There are diverging views as to whether this is only a
transition period problem - suggested by many CAs and the Commission- or if it will continue beyond
2016 as indicated by industry. Furthermore, the proposed introduction of a sub-assembly approach for
points of sale and self-service devices or the issuing of a guidance document have already been
submitted. They are under review and analysis in the relevant working groups of WELMEC. However,
there is no consensus on the appropriate solution to this point.
In relation to the impact of the Directive on technological innovation, there are questions raised
concerning the appropriateness of using the OIML standards. The supporting WELMEC documents are
seen as rather prescriptive but no strong negative or positive impact could be identified. In that respect,
it is claimed that the strict adherence to WELMEC guidelines by a number of notified bodies contributes
to the creation of obstacles and limitations. Another reported problem concerns the limitations of real
market tests of new systems since there is no testing period allowed by the Directive.
38 A Point of Sale (POS) system is a system for managing the sales of goods. The term refers to the software and
hardware associated with check-out stands, and all of the bundled features which are included. 39
See also a description of the mix and match issue in the table concerning MI-005a in Annex E and in section 6.1.
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The 10-year transition period is considered by industry as prolonging the problematic situation
concerning the combination of new and old equipment and has led to a delay in the introduction of new
MID-certified equipment. On the positive side it has helped companies that were not adequately
prepared.
The administrative costs linked to the implementation of the Directive appear to be at rather similar
levels as in the past, although this can vary among notified bodies and types of certification procedures.
Companies present in multiple markets (which are most of the main players in the EU market) suggest
that they still benefit from the reduction of certificates.
The level of market surveillance was also highlighted as rather poor in most countries – limited to the
CE+M marking and document tests – and completely absent in a smaller number of them. Still, there
was no evidence of problems of unfair competition provided.
Finally, the industry is actively represented in the relevant procedures and discussion in the relevant
working groups of the MID and of WELMEC and the views expressed are given proper consideration.
However, from the industry side it is proposed that the importance of WELMEC in the implementation
of the Directive - through the issuing of guidance documents and the formulation of proposals for
solving various issues – makes their observer status inadequate.
MI-005b – Other liquid dispensing systems
As in the case of fuel dispensers, there is a rather mixed view regarding the experience of the
implementation of the Directive so far. It balances the clear benefits from the use of a single
certification for accessing a wider market with a number of problems/issues that manufacturers face
that include:
- The national regulations concerning the use of instruments – thus not covered by the MID - which
in some cases create market barriers
- the limitations concerning the combination of new and old equipment for the revamping of
dispensers in fixed installations
- the requirements concerning the certification of modified equipment with additional MID
certificates for, what are considered by industry, minor modification to MIs. They increase the total
administrative costs for each product even if costs for issuing each certificate by notified bodies has
not changed drastically
- the limitations posed to manufacturers of separate equipment/components – mainly SMEs – that
cannot be MID-certified that, as suggested, benefit large size firms of complete systems. However,
this change is not as radical given the 10-year transition period and the fact that a full system
approach was already introduced in the national legislation of most Member States even before the
MID.
The optionality principle has been used by a number of countries (5) for specific sub-categories of
dispensers. The main reasons are the absence of such instruments in the country or the view of
governments and stakeholders that the introduction of regulation would pose additional administrative
costs without bringing benefits to consumer protection beyond those applicable by general consumer
protection legislation. The findings of the study did not identify evidence of a two-tier market of legal
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metrology instruments, of unfair competition or of any consumer protection issues as a result of
optionality.
Unfair competition was reported but it is primarily seen as a result of the reported limited market
surveillance in a few Member States, particularly among the new Member States and the south.
Finally, as in the case of petrol dispensers, the representation of industry stakeholders in the MIs
committee is adequate. However, the observer role in WELMEC is not considered appropriate by
industry.
4.6 MI-006 – Automatic Weighing Instruments
The key finding of the analysis of the implementation of the MID in relation to the Automatic Weighing
instruments is that the adoption of the international standards and single certificate represent a very
important contribution of the Directive. It has facilitated the operation of the single market and led to
important cost savings in terms of overall certification costs to firms. However the practical experience
concerning the implementation of the MID, including the operation of the notified bodies, the market
surveillance and some of the administrative work required are problematic and, as a result, limit the
effectiveness of the Directive.
In relation to technological innovation the dominant view of industry is that the MID provides ample
space for technological innovation based on the generic essential requirements following OIML
recommendations. However, the use by notified bodies of WELMEC guidance documents “as if they
were law” – i.e. representing the only way of conforming to requirements – is seen as delaying the
process and restricts the willingness of some companies to develop innovative solutions.
Optionality has been used by a small number of countries (IE, MT, CY, SE, UK, CH) and primarily
concerned rail weighbridges due to the absence of these categories of instruments in the domestic
market. CECIP referred to one country where optionality was used to favour domestic production but no
specific example was provided. Overall, while individual cases cannot be excluded, companies did not
identify important problems in terms of unfair competition or consumer protection due to the use of
optionality.
Some, rather limited, issues of consumer protection are seen as a result of the limited and
problematic market surveillance which, as suggested by the industry, only focuses on administrative
issues (CE+M marking and supporting documents). The use of golden prototypes40
was cited by some
manufacturers although CECIP did not provide information on the relevant country or the extent of the
problem.
Concerning administrative costs, the evidence suggests a small increase in the costs of a single
certification but this is clearly outweighed by the savings of the use of single certificate. These savings
are clearly greater for larger firms with presence in multiple markets.
Finally, in terms of representation in the relevant MID procedures, the sector is adequately and actively
represented through CECIP in the relevant working groups although there are reservations concerning
40 Use of prototypes that comply with essential requirements in order to acquire the MID certificate but
subsequent production of sub-standard products.
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the capacity to follow all working groups and to monitor all working documents and the extent that their
inputs are taken into account.
4.7 MI-007 – Taximeters
The overall experience from the implementation of the MID in relation to taximeters indicates that the
Directive has not yet led to the creation of an efficiently operating single market. However, at the
same time, it has not created any problems and obstacles in relation to the circulation of products in
the market or the development of new products and innovation.
Non-MID related national legislation concerning tariffs structures and the use of taximeters remain the
most important applicable regulations that represent, according to manufacturers, the main obstacles
towards the development of an effective single market. Still, such a problem should not be overstated
since the few multinational companies in the sector are present in a large number of EU countries.
The costs and the time required for certification by notified bodies appear to have increased since the
introduction of the MID although, for those firms with presence in multiple countries, they are
outweighed by the relative costs reductions from the use of a single certificate. Rather more
problematic for firms is the inconsistent approach of notified bodies in interpreting essential
requirements.
In the case of taximeters the optionality principle is used only in one country (CH). Although one
company complained about unfair competition, the evidence suggests that, as in most other sectors, it
is the problematic market surveillance in some Member States (particularly in the UK). It allows non
MID-certified taximeters to compete unfairly in specific local market against MID-certified ones based
on a lower price.
Most probably due to the absence of a relevant European association the taximeters sector is not
represented in the MID working group or WELMEC although companies did not appear to consider this
as a particularly problematic issue.
4.8 MI-008 – Material measures
The analysis of both sub-sectors falling under MI-008 (Material measures of length and Capacity serving
measures) indicates that the impacts of the Directive have been limited and that for most firms the
implementation of the Directive has been “business as usual”. Still, the representatives of length
measuring instruments claimed that the introduction of a single certificate has helped reduce trade
barriers across countries.
In relation to technological innovation, the sector is predominantly low tech and industry
representatives did not see MID playing any particular role, positive or negative. However, for the
more high tech length measuring instruments that incorporate software components (e.g. based on
radar and x-rays), the requirement for recertification for what industry considers minor changes in the
software is seen as creating additional costs but also a possible disincentive for introducing new
products.
As far as optionality is concerned, five Member States have chosen to opt out and did not introduce
legislation. The basis for the decisions was that regulation would impose burden on firms and the
enforcing authorities without offering corresponding consumer protection benefits. However, the
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presence of two tier markets with non CE+M marked instrument in these sectors is not a result of
optionality but the fact that large number of these instruments are not used for legal metrology
purposes (e.g. drinking glasses not used for measurement or length measuring rods or tapes used in
households).
The findings of the analysis indicate that in general the administrative costs linked to the certification
process have not changed significantly. For those companies with focus on the domestic market there
are probably some increases in costs on the basis of some additional MID documentation and the new
machines bought for CE-marking. Given the low unit value, these costs are seen as relatively high.
However, the use of a single certificate brought overall cost savings for firms engaged in a large number
of markets.
4.9 MI-009 – Dimensional measuring instruments
As with MI-008, the findings indicate that the overall changes to the market as a result of the Directive
have been rather limited. However, the use of a single certificate has helped reduce trade barriers
across Member States.
As in the case of MI-008 industry representatives did not see MID playing any particular role in terms
of technological innovation since the sector is rather low-tech. For the more high tech instruments that
include software the requirements for recertification for minor changes is seen as delaying the
innovation process.
As far as optionality is concerned, nine Member States have chosen to opt out and have not introduced
legislation in relation to MI-009. The basis for the decisions was that regulation would impose burden to
firms and the administration to enforce without offering consumer protection benefits. Companies did
not provide evidence of unfair competition and presence of a two tier market. The presence of non
CE+M marked instruments in these sectors is, as in other sectors, not a result of optionality but the fact
that larger number of these instruments are not used for legal metrology purposes (e.g. drinking
glasses or length measuring rods or tapes used in households).
The information collected also indicates that administrative costs linked to the certification process
have not changed significantly. For those companies with a focus on their domestic market the overall
costs and benefits were limited while for those engaged in a large number of markets the use of a single
certificate does indeed bring some cost savings.
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4.10 MI-010 - Exhaust gas analysers41
The evidence and interviews from the sector suggest that the MID had contributed towards the
development of a single market based on the use of a single certificate. The EU certificate has also
helped raised the quality of the products in the market. However, there are strong indications that MID
certified instruments remain a minority in a number of EU countries42
. Certified inspection centres
(MOTs), the main users of MID-certified gas analysers still use older non-MID certified instruments.
The industry reports that the market is also limited by the fact that the MID covers only 4-gas analysers
for cars that consume petrol and not analyzers for smaller number of gases emitted for motorbikes or
those that consume diesel. These are still nationally controlled. As a result, manufacturers of most
analysers are still required to apply for national certificates for the same equipment and thus lose
important part of the benefits derived by the MID.
In relation to the impact on technological innovation, the MID itself does not appear to have any
positive or negative effect. The interviews indicate that the adoption of the OIML guidelines in the
definition of the essential requirements brought only limited technical changes.
In terms of administrative costs, the information collected indicates a small increase in the costs for
obtaining a single certificate but, according to EGEA, the use of a single certificate has reduced red tape
and benefited a sector dominated by small firms.
Finally, in terms of stakeholders representation, the relevant trade association – European Garage
Equipment Association - has not been involved in the working group of the MID or the relevant WELMEC
meetings.
41 The analysis of this category of MIs is based on limited input. EGEA – the main representing association – was
not available during the period of the fieldwork but stated that it intends to send comments after the completion
of the study. 42
The representative of UK Garage Equipment Association made reference to only 6 MID conforming gas analysers
approved so far in the UK. Data from other countries were not available.
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This section contains an analysis of two surveys carried out during the study. These are a survey of
notified bodies conducted by CSES during Phase 2 of the study and the SME pilot survey that was
organised by the European Commission. In this section we present the analysis of the findings. The
surveys complement the data in the previous section provided by the interviews and documents.
5.1 Notified bodies survey
The notified bodies (NBs) survey was conducted during the period March-April 2010. It targeted the 140
notified bodies that have been designated by competent authorities in the Member States to assess and
certify conformity in accordance to the MID Directive for one or more categories of measuring
instruments and conformity assessment procedures (modules A-H1). The list of NBs was extracted from
NANO Database43
. They were contacted electronically and invited to participate in an online survey that
was available in five languages (EN,DE,IT,FR,ES). The invitation to the notified bodies was followed by
two reminders and the survey was closed on 30 April.
By the close of the survey, CSES had received 39 responses that represented a response rate of 27.8%,
which is a relatively high rate for such a survey. The NBs that participated in the survey covered 12
countries. According to the data provided and the information collected from WELMEC database, the
response represents 47% of the total number of EC type certificates (including updates) issued during
the period 2006-2009. The four most active notified bodies in Germany, Netherlands, France and the UK
participated in the survey44
.
Finally, the survey covered all categories of measuring instruments falling under the Directive and all
MID modules. MI-005 (petrol dispensers and other systems for liquids other than water) were the most
widely covered. In terms of modules, module F (third party product verification) was the most common
followed by modules B (EC type examination), D (self-verification of production process and G (Approval
and verification of one off instruments). Modules C and C145
are covered by only one NB are not
applicable in any of the categories of measuring instruments according to the MID.
Table 5.1 – Measuring instruments and modules covered by the Notified bodies that participated in
the survey
Measuring instruments covered by surveyed NBs
By MI sector covered Number
MI-001: Water Meters 22
MI-002: Gas Meters & Conversion Devices 22
MI-003: Active Electricity Energy Meters 22
MI-004: Heat Meters 22
MI-005: Measuring Systems for Liquids other than water 31
MI-006: Automatic Weighing Instruments 30
43 Available from
http://ec.europa.eu/enterprise/newapproach/nando/index.cfm?fuseaction=Directive.notifiedbody&dir_id=12564
1&type_dir=NO%20CPD&pro_id=99999&prc_id=99999&ann_id=99999&prc_anx=99999 44
Participants did not have to state the name of the NB but were asked to indicate if they wanted to be contacted
and to provide the necessary contact details. 45
Module C: Declaration of conformity to type on the basis of internal production control. Module C1 : Declaration
of conformity to type on the basis of internal production control plus product testing by notified body.
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Measuring instruments covered by surveyed NBs
By MI sector covered Number
MI-007: Taximeters 18
MI-008: Material Measures 28
MI-009:Dimensional Measuring Instruments 19
MI-010: Exhaust Gas Analysers 13
By Module covered Number
A1 - Internal production control plus product testing by a notified body 15
B- Type examination 17
C - Conformity to type based on internal production control 1
C1 - Conformity to type based on internal production control plus product testing by a notified body 1
D - Conformity to type based on quality assurance of the production process 15
D1 - Quality assurance of the production process 12
E - Conformity to type based on quality assurance of final product inspection and testing 12
E1 - Quality assurance of final product inspection and testing 10
F - Conformity to type based on product verification 30
F1 - Product verification 23
G - Unit verification 17
H - Full quality assurance 8
H1 - Full quality assurance plus design examination 11
Clarity of supporting documents and procedures
The focus of the NBs survey was the assessment of the extent to which the MID related standards (EN
standards, OIML related documents and the relevant guidance documents issued by WELMEC) were
clear and helpful. It focused on the clarity of guidance for the testing of the conformity of the MIs but
also the guidance on the conformity assessment procedures. The questions intended to assess whether
the claims by industry and conformity assessment bodies concerning the consistency of the notified
bodies were shared by the notified bodies themselves. Although it was not possible to ask notified
bodies to compare their work with other NBs, the stated level of clarity of the various documents
provides a relevant indication.
Overall, the notified bodies’ responses suggest that the existing MID documents are appropriate and
helpful. The majority of NBs (over 56%) found that EN standards and OIML documents were very clear
or clear while some 30% provided a neutral response. Only one stated that the standards are unclear. In
the case of the guidance documents on the OIML documents and the essential requirements, the
responses were rather less positive although again the number of NBs that expressed a negative view
was small. Around 45% of NBs had a positive view of the guidance while only 10% considered that the
guidance on the OIML is unclear and 16% stated the same concerning the guidance on the essential
requirements.
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Table 5.2 - In relation to the testing of conformity of measuring instruments, how clear do you find the
different MID documents available? (Notified bodies responses)
EN standards OIML normative
documents
Guidance on OIML
normative documents
Guidance on essential
requirements
Very clear 1 3.2% - 0.0% 1 3.4% 2 6.7%
Clear 17 54.8% 18 56.3% 13 44.8% 11 36.7%
Neutral 9 29.0% 11 34.4% 9 31.0% 11 36.7%
Unclear 1 3.2% - 0.0% 2 6.9% 5 16.7%
Very unclear 0.0% - 0.0% 1 3.4% - 0.0%
Don’t exist 2 6.5% 2 6.3% 1 3.4% - 0.0%
No opinion 1 3.2% 1 3.1% 2 6.9% 1 3.3%
Total 31 100% 32 100% 29 100% 30 100%
No answer 8 7 10 9
Total surveyed 39 39 39 39
Source: CSES survey
The results are replicated more or less in the same way for all categories of instruments. When cross
tabulating the responses for each of the 10 sub-sectors we did not find any statistically significant
differences from the overall picture.
Small differences were more apparent when comparing notified bodies from old and new Member
States but again the responses do not reveal fundamental differences (see table 5.3).
Table 5.3 – Comparison of responses of notified bodies in new and old Member States concerning the
perceived clarity of MID documents available? (% of notified bodies responding out of 29 from old
Member States and 8 new Member States46
)
EN standards
OIML normative
documents
Guidance on OIML
normative
documents
Guidance on
essential
requirements Total
old MS new MS old MS new MS old MS new MS old MS new MS
Very clear -
clear 56.6 71.4 56.5 62.5 54.5 0.0 43.5 50.0 58.0
Neutral 30.4 28.6 39.1 25.0 27.3 50.0 34.8 50.0 29.0
Unclear -
very unclear 4.4 0.0 0.0 0.0 13.6 0.0 21.7 0.0 3.2
No opinion
-not exist 8.8 0.0 4.3 12.5 4.5 16.7 0.0 0.0 9.7
Total 100 100 100 100 100 100 100 100 100
Source: CSES survey
The second relevant question concerned the application of the conformity assessment procedures and
the role of the relevant documents (standards and WELMEC guidance). As it is shown in figure 5.1, the
majority of the notified bodies (over 50%) considered that both the standards and the WELMEC
documents were quite clear. Still around one third of NBs were rather sceptical of the contribution of
EN-standards and over 40% of the WELMEC guidance documents.
46 Two notified bodies did not state country of operation.
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Figure 5.1 - In relation to the application of the different conformity assessment procedures, how
clear do you find the different MID documents (standards, guidance on conformity assessment
procedures)? (% of notified bodies responding)
Source: CSES survey
The following text box presents the comments made by notified bodies. They include points referring to
the need to have the OIML documents available in different languages to more specific and technical
issues related to specific modules that are seen as inappropriate, unclear or missing.
Text box 5.1 – Comments of NBs on the clarity and usefulness of the documents of the MID (category
of MIs covered by NB)
Some harmonised standards are declared as giving full presumption of conformity although it was not the case.
The annexes are not enough clear and accurate. (MI-001-MI-010)
Our designation requires us to use standard forms that I have found unusable and inappropriate for certain
verifications. (MI-005, MI-006, MI-008)
There is no harmonized documentation for module B for MI-005 and this has resulted in one notified body
rejecting EC Type Examination Certificates from another. We still feel that Member States are more interested in
keeping status quo and interpreting OIML R117-1 as the legal basis rather than the Directive itself. (MI-005)
One problem is from our opinion concerns issuing the certificate for module H1. There is no pattern in any guide
how such a certificate should look like. (MI-003)
3.0%
0.0%
54.5%52.9%
24.2%
32.4%
6.1%
8.8%
12.1%
5.9%
0%
10%
20%
30%
40%
50%
60%
EN standards Guidance on conformity assessment procedures
Very clear clear neutral unclear very unclear not exist no opinion
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Normative documents are not available in German language. There are no clear requirements for gas meters
measuring volume under reference conditions and there are different interpretations from NAWI to MID (MI-
006). (MI-001-MI-010)
In some cases the modules are not sufficiently defined and produce different interpretations among different
Member States.(MI-001- MI-010)
It would be useful to have WELMEC guides translated into Italian in order to avoid conflicting advice.(MI-006, MI-
008)
The module F concerning the application of statistical procedure described is inaccurate. There is currently no
approved standard for the statistical method of module F. (MI-001-MI-004)
The drafting of the EC-type examination certificates with respect to scope and requirements for the tests varies
widely. There are also problems with the language versions of the examination certificates (MI-001- MI-010)
There is not clarity in respect to the following question: Is a conformity assessment necessary when rebuilding an
MID certified instrument? Furthermore, normative documents as well as harmonized standards should also be
translated into German. (MI-005 – MI-010)
Technological innovation
Based on their direct involvement with the implementation of the Directive, NBs are also well positioned
to assess the extent to which the Directive and the essential requirements support or create obstacles
to innovation to manufacturers.
The responses of 39 notified bodies indicate that the majority of notified bodies (56%) considered that
the Directive is not an obstacle to innovation. Furthermore, there were no significant deviations
depending on the category of instruments with the possible exception of gas analysers were close to a
half of the 13 respondents were rather negative. The comparison among notified bodies operating in
new and old members’ states did not indicate differences in views although a high proportion of NBs –
almost 50% - from new Member States did not provide a response, possibly due to their limited
experience.
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Figure 5.2 - Based on your experience so far, do you think that the essential requirements of the MID
allow technological innovation by manufacturers? (Notified bodies – 39 responses in total)
Source: Notified bodies survey
In order to acquire more information on possible specific obstacles we asked notified bodies to
elaborate further on their position. Among the responses provided (see text box) there is a variety of
responses including those that consider a particularly positive and promoting role, to more balanced
approach considering a rather technology neutral approach and those that consider that there are
specific obstacles as a result of the requirements. Specific issues raised concern smart meters and the
software issues that notified bodies consider as rather problematic. There was also reference to x-ray
checkweighers that are not covered by MI-006 of automatic weighing instruments as an example of
technologically advanced MIs that should also be included. The comments provided in Text box 5.2
illustrate the points raised by some notified bodies but are not necessarily representative.
Text box 5.2 – Comments of notified bodies on the role of the MID in technological innovation
To make products based on the requirements MID requires manufacturers to innovate technologically. (MI-006,
MI-008)
The MID allows enough flexibility for the manufacturer to develop specific solutions and innovations. (MI-001-MI-
004)
MID provides a framework and only very few restrictions. (MI-005)
The essential requirements are sufficiently independent from specific technologies to allow innovation. We have
22
1112 12
11
18 18
11
16
11
7
10
76
7 7
98
6
8
6 67
4 43
4 4 4
1
4
2
0
5
10
15
20
25
Total MI001 MI002 MI003 MI004 MI005 MI006 MI007 MI008 MI009 MI010
YES NO no answer
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never experienced a problem until now. (MI-001- MI-010)
The essential requirements are sufficient and allow manufacturers to develop the electronics of the meters. (MI-
001-MI-006)
In general the essential requirements of the MID allow technological innovation by manufacturers. As an
exception the case of smart meters should be pointed. Lack of definitions and requirements hinders the
development of such instruments.(MI-001-MI-008)
In general yes with the exception of specific cases such as remote management in smart meters.(MI-001-MI-010)
No, because of the complexities of the requirements that are not particularly helped by the guidance/normative
documents. We also do not think software issues have been well addressed. (MI-005, MI-006, MI-008)
The responses of the notified bodies seem to be in line with the views of most competent authorities
and manufacturers. The experience from the implementation of the Directive so far tends to be positive
and the existing tools supporting the NBs and manufacturers in the implementation of the Directive
(standards, guidance documents) are assessed positively although in specific categories of instruments
there are possible problematic areas. In relation to the question of technological innovation, there is no
evidence that the Directive poses important obstacles to innovation with the exception with the already
documented issue of smart meters. Having said that, the survey suggests that there is still scope for
clarifications of the relevant documents. The results also corroborate the suggestion by a number of
manufacturers and competent authorities that there are problems of consistency in the interpretation
by the notified bodies of the essential requirements and the conformity assessment procedures.
5.2 SME survey
The SMEs survey analysed in this section was carried out by the Commission services using an on line
survey tool with a panel of SME companies. The survey was opened on 30 September 2009 and closed
on 5 December 2009 and attracted 286 responses.
Characteristics of the respondents
The respondents of the survey were primarily small enterprises of less than 50 employees (over 80%)
with over 50% being micro enterprises of less than 10 employees. In terms of sales, the majority (63%)
stated total turnover of less than €10million although 34% did not provide any data.
Table 5.4 - What is your annual turnover
Distribution of respondents by turnover (€s) Distribution of respondents by number of
employees
Options № % Options № %
<100,000 32 11.9 <5 74 25.9
100,000-1,000,000 97 33.9 5 to 9 95 33.2
1,000,000-10,000,000 50 17.5 10 to 49 62 21.7
>10,000,000 10 2.5 50 to 249 10 3.5
No answer 98 34.3 Over 250 45 15.7
Total 286 100 Total 286 100
The participants in the survey were primarily manufacturers (27%) or users of MIs (44.8%). Installers,
distributors and importers were also well represented in the survey.
Table 5.5 -Type of activity in relation to measuring instruments
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36
Number of companies that stated as: № %
User 127 44.4%
Manufacturer 77 26.9%
Installer 48 16.8%
Distributor 47 16.4%
Importer 37 12.9%
Other 17 4.5%
Manufacturer and other (importer, distributor, installer) 32 11.2%
In terms of the country of origin, the sample provided a wide coverage of EU countries (see Table 5.6)
but there is a notable absence of users from the Netherlands or the United Kingdom. The countries with
the largest number of respondents were Italy, Poland and Hungary.
Table 5.6 - In which country are your headquarters located?
Country № % Country № %
Austria 6 2.1 Luxembourg 4 1.4
Czech Republic 23 8.0 Poland 30 10.5
Estonia 2 0.7 Portugal 11 3.8
Finland 1 0.3 Romania 10 3.5
France 23 8.0 Slovakia 5 1.7
Germany 24 8.4 Slovenia 9 3.1
Hungary 27 9.4 Spain 20 7.0
Italy 35 12.2 Other/not stated 42 14.7
Lithuania 14 4.9 Total 286 100.0
In terms of the types of measuring instruments covered, all sectors of MIs were represented in the
sample. Taximeters, capacity serving measures and exhaust gas analysers were represented by less than
6% of SMEs while, in contrast, SMEs related to utility meters, weighing instruments, length measure and
dimensional measuring instrument were represented by over 15%.
Table 5.7 - Instruments covered (more than one answer possible)
Category of MI № %
MI-001 Water meter 66 23.1
MI-002 Gas meter 45 15.7
Electricity meter 65 22.7
Heat meter 43 15.0
Petrol pump 27 9.4
Other non-water liquid measuring instrument 33 11.5
Automatic weighing instrument 58 20.3
Taximeter 12 4.2
Length measure (tape, dipstick) 53 18.5
Capacity serving measure 14 4.9
Dimensional measuring instrument 56 19.6
Exhaust gas analyser 17 5.9
Non-automatic weighing instrument 58 20.3
Furthermore, for the great majority of the companies in the sample (around 78%), the measuring
instrument they traded had a CE+M marking.
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Figure 5.3 - Is the measuring instrument you refer to marked with the CE+M marking? (% out of total
286 survey participants)
Finally, the sample included companies operating in all 27 EU Member States. France, Germany and
Spain were the most common markets, mentioned by more than 1/5th
of the respondents. Around 19%
stated a market presence in more than five EU countries while, in contrast, 23% were present in only
one – usually their domestic - market. In terms of exports outside EU, around 40% stated that they sold
their products outside the internal market (against 42% that said no), primarily in other countries of
South and Eastern Europe (56%) but also around 35% to non-EU Mediterranean countries , Africa, Asia
and North America.
Experience from the implementation of the Directive
Manufacturers/importers
Turning to the experience from the implementation of the Directive, manufacturers and/or importers of
MIs were asked to indicate which conformity procedures they use and whether they thought that the
conformity assessment procedures are adequate for their needs. While all modules were stated by the
80 SMEs that responded, modules B and D are the most commonly used (44% and 52% respectively)
while modules A, G, F, and H were less often stated.
More importantly, over 80% of the 118 manufacturers and importers were positive or very positive
concerning the adequacy of the modules and no SMEs stated they were inadequate for their needs.
22.4%
77.6%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
No Yes
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Figure 5.4 - Do you consider conformity assessment to be adequate for your needs? (Percentage
responding out of 58 responses – 60 manufacturers/importers did not answer)
When asked for specific comments and suggestions for improving the conformity regulations SMEs
referred to the need to relax the conformity assessment procedures for the inexpensive MIs. They made
suggested the need to extent the use of the modular approach. In addition there were request for
availability of information – including WELMEC documents – in other languages besides English.
A second issue examined was the extent to which manufacturers and importers experienced barriers to
trade with regards to marketing and/or putting into use CE+M marked MIs on the internal EU market.
The answers indicate that the great majority of SMEs do not experience any such barriers.
41.4%39.7%
12.1%
0.0%
6.9%
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
Yes,
completely
Yes, mostly Not always Never Do not know
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Figure 5.5 – Are you experiencing barriers to trade with regards to marketing and putting into use
CE+M marked MIs (% of SMEs – manufacturers/importers stating – total 118 responses)
When asked to state specific problems in relation to barriers to trade, a small number of companies
referred to barriers posed by national authorities that do not allow them to enter other markets. The
complaints concerned mainly – but not exclusively - new Member States but there was no specific
category of MI identified.
Users
The survey also asked SMEs users of MIs to assess whether the current legal metrology regime provides
sufficient protection. The majority of the responses were positive (60%) with only a small share (20%)
suggesting problems in terms of consumer protection.
Table 5.8 – Does the current legal metrology regime provide sufficient protection (users of MIs)
Answers No %
Yes 75 60.0
No 24 19.7
No answer 26 21.3
Total 125 100
Finally, all SMEs were asked whether they were aware of unmarked products competing with CE and M
marked instruments. The answers suggest that there is indeed a significant presence of MI instruments
circulating without CE+M marking as close to 60% of the total respondents made such reference. While
16.1%
83.9%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
Yes No
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20% did not consider that the products created unfair competition an important 40% thought otherwise.
The differences between the responses of users and manufacturers were rather small although a
greater share of users thought that the non-CE+M marked products were competing unfairly. Other
cross-tabulations (based on size of firms or category of instrument) did not indicate differences from the
general picture.
Table 5.9 - Are you aware of unmarked products competing with CE+M marked instruments? (Number
and percentage of manufacturers, users and total number of SMEs responding)
Awareness Manufacturers/importers Users Total SMEs
№ % № % № %
No 41 36.9% 35 41.2% 97 41.6%
Yes, but fair competition 27 24.3% 13 15.3% 45 19.3%
Yes, unfair competition 43 38.7% 37 43.5% 91 39.1%
No response 7 40 53
Total 118 124 243
The findings of the survey suggest that most SMEs do not face different problems compared to those
reported by large companies during the interviews. Barriers to trade due to protection from national
authorities (real or perceived) and costs for conformity assessment that are higher than expected are
reported but only from a small number of SMEs. There are also no categories of MIs identified with
particular issues or problems. From the user’s side, the survey suggests that consumer protection is
adequate. The only issue raised by the SME survey concerns unfair competition by non CE+M marked
products. While this point should not be considered as an SME specific problem, it seems to be more
prominent in comparison to the evidence provided during the interviews with trade associations and,
mainly larger, companies.
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In this section we present the findings of the study in relation to the key evaluation questions. The
effectiveness, impacts and implementation of the Directive are addressed on the basis of the findings
presented in the previous sections.
6.1 Effectiveness of the Directive
Contribution to an efficiently operating internal market
The experience from almost all MI sectors and from the great majority of competent authorities
suggests that MID has quite successfully provided the basis for the development of a more efficiently
operating single internal market with the use of a single certificate for the placement of products in the
European market. The majority of competent authorities refer to a clear contribution of the MID based
on their own experience or, in fewer cases, the feedback they have received from industry. From the
industry side, in most MIs’ sectors clear benefits from the use of a single MID-certificate are recognised
and, in a small number of cases, it has been indicated as the main driving force for the expansion of
firms to other markets inside the EU. In the case of utility meters (MI-001-MI-004), they supported
more competitive public procurement procedures with potential direct benefits in terms of quality and
price to the utilities and the final consumer.
Having said that, specific problems and obstacles have been documented which are more or less directly
linked with the implementation of the MID. They are either crosscutting issues or more sector-specific.
They include:
• The barriers posed by some national and local authorities by setting additional requirements or, in
some cases, regulations concerning functionality, marking or the use of instruments (e.g.
additional/different seals for fuel dispensers in IT and ES or a different tariff structure for taximeters
in the UK). In the majority of cases, these issues concern the use of MIs and they are not governed
by the MID. According to manufacturers of fuel dispensers and taximeters, there are restrictions
that create barriers to entry by increasing costs and by obstructing the operation of the single
market. However, the respective competent authorities questioned on this topic denied wrongdoing
or appeared unaware of such issues. Use-related requirements are, rightly or not, seen as a prime
responsibility of Member States or local/regional authorities. Consumer protection or other
concerns are considered of greater priority than possible obstacles to the smooth operation of the
single market in relation to legal metrology instruments.
• There are a few cases where national authorities (eg Italy and Spain for fuel dispensers and France
for taximeters) are reluctant to accept MID certificates from other countries without conducting
their own additional controls. Whilst such checks may concern in-use requirements, a number of
interviewees from industry and competent authorities indicate that there may be a problem of
understanding – or accepting - what the implementation of a new approach Directive entails.
• There appears to be limited information on the applicability and the requirements of the MID from
an important number of manufacturers and, even more so, importers of measuring instruments.
Cases of products brought to market without the necessary CE+M marking as a result of limited
awareness of the requirement were reported by few competent authorities (e.g. SE, IR, MT).
Industry associations also recognise this as a problem, particularly for small firms with limited
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capacity and resources to follow the various regulations. Still, while it is an issue that merits
attention, the existing evidence does not suggest that it is a particularly acute problem.
• A well-documented issue with impact on the market for fuel dispensers and other liquid dispensing
systems concerns the so called “mix and match” issue and the capacity to combine new and old
components for these categories of instruments. As already described in Section 4.5 existing petrol
stations with “old” non-MID certified petrol dispensers and points of sale (POS)47
may not be
connected with new MID certified equipment to form a new system unless the whole system is re-
certified under MID. Furthermore, existing fixed installations approved according to the old national
legislation can be placed on the market and put into use during the transition period, but they
cannot be altered. A system approved under old national legislation cannot be upgraded with an
MID certified component without first seeking MID approval for the complete system. For users this
means that they may not install new components of a system without first asking the manufacturer
of the fuel dispenser to upgrade the system. Otherwise, they are required to buy complete systems.
Furthermore, petrol stations’ owners that want to revamp part of a system are forced either to
repair old non-MID dispensers or points of sale stations or to buy complete new systems. Among the
30 countries, only the UK and the Netherlands’ authorities enforced this requirement48
while the
remaining have selected either not to require any certification for the points of sale in continuation
to the pre-MID practice or to allow the mixing and matching.
According to the data provided by industry the market implications of this appear to be significant in
some countries. At least in the UK there is reported unwillingness of owners of petrol stations to
install new MID certified dispensers. As a result old non-MID certified dispensers cover over 80% of
the local market. Furthermore, small size producers of self-service devices or components are in an
unfavourable position against large firms that develop and sell complete systems. In relation to the
overall size of the market, the problem remains limited due to various legal arrangements49
that
most national governments have adopted during the transition period. Furthermore, by the end of
the transition period a great share of MIs and points of sale will have completed their life cycle50
.
Still, it is the opinion of most stakeholders involved (authorities and industry) that the current
arrangement is not satisfactory. The proposed solution to the problem based on the definition of
self-service devices and components as sub-assemblies is supported by a large number of
stakeholders, but it is not unanimously accepted by all Member States.
It can be claimed that, with the exception of the sub-assembly issue, most of the problems raised can be
seen as symptoms of an initial “teething period” and indeed this is a view shared by a number of
competent authorities (e.g. DE, NL, and PT). Over time, as experience builds up and information is
further disseminated, obstructing practices based on the old regime should be expected to diminish.
Information exchange and targeted campaigns at the national level could help in this direction.
47 A Point of Sale (POS) system is a system for managing the sales of goods. The term refers to the software and
hardware associated with check-out stands, and all of the bundled features which are included. 48
In both countries arrangements have still been made by national authorities allowing the combination of old and
new components based on presence in the system of at least one MID certified dispenser or POS. 49
Allowing the mixing of old and new or not having any regulation. 50
This is a point that is still disputed by CECOD, arguing that since non-MID certified are still sold in some markets
they will still be in operation long after the end of the transition period in 2016.
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Furthermore, it is clear that the issue of use-related requirements in MIs posed by Member States and
the limitations to the development of a single market cannot just be solved in the context of the MID
but is a wider issue.
Role of the Directive in promoting or inhibiting technological innovation
The existing empirical evidence and the results of the notified bodies’ survey indicate that in most
categories of instruments the MID has not affected technological innovation to any material extent. It
appears to be technologically neutral allowing for a level playing field. For most categories of MIs, the
industry did not consider that the Directive posed particular obstacles to technological innovation even
if, at the same time, it did also not consider that it had any supportive role. The economic incentive of
easier access to a broader market was the only benefit explicitly stated but only in a few occasions. The
notified bodies survey also seems to support a neutral, if not positive, role of the Directive.
Still, there a few areas where the implementation of the MID appears to create potential or real
barriers:
• In a few categories of MIs (e.g. MI-005) the essential requirements of the Directive are seen as
either restrictive or rather prescriptive. Industry and some competent authorities refer to limitations
in terms of the classes and types of instruments allowed (e.g. exhaust gas analysers only for cars)
and the capacity for the conduct of market trials in the case of fuel dispensers.
• A more important problem seems to be the restrictive use by notified bodies of WELMEC guidelines
and the constraints that they pose in accepting alternative approaches to conform to the essential
requirements of the Directive. While WELMEC guidelines are not requirements, both industry and
competent authorities report that many notified bodies tend to use WELMEC guidance documents
as if they were. As a result, they require extra testing or more time in the case that the proposed
approaches deviate from WELMEC guidelines. A few cases of unwarranted rejections – from the
point of view of the manufacturers - were also reported. The feedback of the notified bodies does
not suggest particular problems in the interpretation of the relevant documents that could be the
source of such an approach. A risk averse approach and the limited experience of some of them
appear to be the most probable cause.
• A specific issue related to the utility sector concerns the use of smart meters. The dominant view is
that the current provisions of the Directive do not provide an optimal solution especially in view of
the technological and market developments that are already taking place. Most technologically
advanced Measuring Instruments usually include a software system and a system allowing for
remote reading (tele-metering) as well as more complex displays showing additional information
such as different tariff periods and related costs. The MID provisions do not provide rules either on
the software, display or on the remote sensor component of the meter. The Energy Performance of
Buildings Directive and Energy Efficiency Directive require Member States to develop national plans
to install smart meters. Stakeholders suggested problems in the development of a functioning single
market for smart meters due to a continuing need for national certifications of the software or the
tele-metering component, possibly in breach of the MID51
.
51 The industry did not provide specific examples illustrating this more clearly.
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There is no agreement as to what constitutes the most appropriate way forward. The adoption of a
sub-assembly approach is favoured by a large number of stakeholders - but it is not universally
accepted – while reliance on WELMEC documents is not considered as a sound basis for a coherent
approach by itself. Furthermore, smart meters are not only an MID issue. There are currently no
standards for the inter-operability of the meters in smart gridding systems, allowing for a more
complex management of energy sharing. It is therefore clear that smart meters regulation has far
further implications than a purely metrological one. Further experience and analysis appears to be
necessary at this stage.
Evidence of the development of two tier market and unfair competition – role of optionality
The optionality clause of the MID has been used by a number of countries for a number of instruments
(See Appendix F). In total, according to the most recent reports 15 EU and two EEA countries have opted
out from the Directive for one or more instruments although still around 90% is covered52
. Optionality
has been used mainly by the UK (19 of the total of 36 sub-categories of MIs), Sweden (18), Ireland (12),
Netherlands (11) and Cyprus (10). Poland (7) and Norway (9) have also used it in a number of occasions.
Material measures (MI-008), dimensional measuring instruments (MI-009) and heat meters (MI-004) are
the instruments for which optionality has been mainly applied. The main underlying reasons tend to be
the absence of specific instruments in the market or the consideration by a number of authorities that
regulation may pose additional and unnecessary legislative burdens without providing any additional
consumer protection.
A number of stakeholders have still expressed their disagreement with the concept of optionality in
principle but they would still not make reference to problems as a result of its use. Unfair competition
was only rarely mentioned and it was not, in most cases, linked with the absence of regulation in the
specific sector or country. The only area where optionality is possibly linked with unfair competition
concerns taximeters. Industry reported that in the two countries that opted out of the MID (Norway and
Switzerland), cheaper non-MID certified taximeters tend to be the norm and compete unfairly.
However, Member States’ authorities did not consider that the overall costs of regulation justified the
introduction of regulation.
Furthermore, two tier markets – wherever present – are not linked with optionality. Two tier markets
are present for instruments that may also be used for non-legal metrology purposes (weighing
instruments, material measures, dimensional measuring) from companies in their production process or
for domestic purposes. Such non-legal metrology instruments may be identical to instruments covered
by the MID, but their placement in the market is, according to article 2 of the MID, not controlled by
national regulation as far as metrological issues are concerned. Accordingly, these parallel markets will
continue in the future irrespective of any possible changes to the MID, including any changes to the
optionality clause. A few manufacturers mentioned that in some cases competitors claim that their
products are not used for legal metrology purposes in order to avoid complying with the Directive.
However, this is again mainly an issue of ineffective market surveillance and is should not been linked
with the use of optionality.
52 857 of the total of 972 (27 Member States multiplied by 36 categories or subcategories of instruments).
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Contribution to the protection of consumers and users – role of optionality and other factors
The evidence indicates that the Directive has not led to significant changes to the level of consumer
protection and has not jeopardized consumer protection. The modifications to the essential
requirements in comparison to the pre-existing regime were rather small and, in many cases, they were
already integrated in the OIML standards or European standards that the industry had already adopted.
Still, for some countries, especially in the new Member States, competent authorities considered that
the implementation of the Directive did help increase the standards applicable to some MIs. The
benefits to consumers are expected to materialise only gradually as more MID-certified instruments
enter the market.
In relation to the role of optionality, some industry representatives and competent authorities did not
consider it fitting with EU-wide consumer protection but there was no evidence provided of any
problems to consumer protection in the countries used.
Specific issues are raised by some stakeholders (CAs and industry) concerning a few categories of MIs
and relevant provisions of the MID. They included the absence of legal certainty concerning the existing
requirements in Annex I for the display of legally important results, the need to cover additional classes
for some categories of utility meters that used by consumers or the requirements on clock and multiple
registers in utility meters. Such concerns have already been documented in the context of WELMEC and
alternative solutions are examined.
The more important problems concerning consumer protection are linked with what is broadly
considered as problematic and ineffective market surveillance (examined further below) in some
countries or sectors that allows the entry and circulation of non-certified products. Specific examples
provided concerned taximeters in the UK and fuel dispensers and weighing instruments in Greece, some
new Member States, mainly Bulgaria and Romania and, less so, Italy. The interviews with competent
authorities in at least one of the countries confirmed the existence of the problems reported.
Effective representation in the Measuring instruments decision making procedures
The general picture is that the MID decision-making procedures are open for input, comment and
contribution by all interested stakeholders. There is no evidence that interested parties have been
excluded or that they did not have the opportunity to raise issues properly.
Among the manufacturers of the ten categories of instruments, six (MI-001-MI-006) are almost
constantly represented in the working group meetings with frequent participation of the MI-008
(material measures of length and dimensional measuring instruments) by the European Hand Tools
Association. Representative of stakeholders in the remaining categories have not participated in the
meetings either because they do not exist (Taximeters), they have no information on the applicability of
the Directive (FEVE concerning capacity serving measures) or they do not wish to (EGEA for exhaust gas
analyzers).
Among the actively involved almost all representatives considered that their participation and input in
the working group meetings of the MID is open and satisfactory, despite not having voting rights. Among
the sectors that are not directly involved (mainly MI-007-MI-010) the companies did not consider this as
problematic. The main reason for not being present was their own rather limited interest.
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Rather less satisfactory appeared to be for some Trade Associations (i.e. MI-005 and MI-006) the
participation in WELMEC working groups and in the writing of the guidance documents. They are seen as
rather key for the implementation of the Directive and industry representatives proposed that the
current level of involvement and the observer status they enjoy is inadequate. However, this was not a
view shared by utility meters representatives while, according to WELMEC direction, industry experience
and expertise always represents a very important input to the process.
As far as representation of consumers is concerned, the discussion with the main representatives
(ANEC/BEUC and NORMAPME) at the European level indicated that the monitoring of the MID has low
priority list given their limited resources. Concerning SMEs, the representatives consider that the SMEs
active in the sector are a very small share of the 11 million European SMEs and that their interests are
better represented by the respective sectoral associations.
6.2 Impacts
Impacts in terms of costs or administrative burdens and tangible benefits
It is generally accepted by almost all interviewees that the implementation of the Directive has provided
opportunities for cost cuttings as a result of the use of a single certificate for entering the EU market. In
some cases, the establishment of quality systems have also brought financial benefits on a medium to
long-term horizon.
Nevertheless, the introduction of the Directive has in general led to increases in the fees charged by
most notified bodies due to more thorough tests and it has in general extended the length of the
certification procedure creating additional red tape. In addition, national requirements come on top of
the MID which has not led to any simplification. Furthermore, additional costs arise in the case of the
necessary revisions or updates of certificates even for what companies consider as minor changes in the
MIs.
Competition among notified bodies has not been developed so far and, according to most discussions, it
has not yet led to any significant reduction of fees. Based on the information provided the fees charged
by notified bodies for a single certificate have increased in some countries (e.g. 20% in DE, 10-15% in NL)
while in others remained more or less the same (e.g. SL, AU). However, as suggested by some notified
bodies, while the tests required are more demanding competition has helped keep prices down.
Brought together, the extent to which these benefits of a single certificate outweigh the increased
administration costs related to the certification process vary. Firms with greater presence in
international markets have, as expected, seen greater benefits while some of the firms with presence in
a single or few markets suggested that in some cases they experienced a small increase in the total
costs.
Concerning the costs to authorities, most have seen a substantial decrease of their workload in terms of
dealing with applications for national certification that are no longer necessary. This reduction is
significant in the countries with small or no manufacturers where most MIs are imported (e.g. small
ones like CY. MT, LU, AU, IE, SL) and certification has already been taken elsewhere. In other countries
with greater manufacturing base (e.g. DE, ES, NL but also PT), there has been no change of the total
workload. According to most competent authorities, the reduction in the workload has not led to a
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greater focus towards market surveillance activities as the focus of surveillance remains on the use of
MIs that are controlled by national legislation and not the MID.
Overall, the introduction of the MID seems to have created some cost savings in relation to the previous
situation. However, these savings appear rather moderate and tend to be unevenly distributed
favouring firms with higher level of exports and presence in multiple markets. Firms that are only active
in the respective national markets may experience higher administrative costs depending on the type of
instrument and the conformity assessment procedures used.
Impact on SMEs
The evidence provided concerning the impact on SMEs indicates that, overall, small firms are not
particularly affected – positively or negatively- as a result of the MID. Only in two sectors (MI-005 and
MI-006)) the industry representatives argue that the absence of a modular approach (certification of
components or sub-assemblies) may operate against SMEs that focus on the development of only
parts/components which cannot be certified. The industry also suggests that the Directive favours
producers that sell the complete integrated systems that can be MID certified but the evidence provided
so far supporting such conclusions has been rather scarce. However, the SME survey did not provide
evidence of widespread problem as only one out of 286 respondents made reference to such a problem.
Furthermore, the SMEs survey does not indicate that SMEs experience barriers to market entry (less
than 15% of responding SMEs stated so). It did not provide evidence that the conformity assessment
procedures are particularly burdensome (85% of SMEs responding stated that the procedures are
adequate).
Finally, SMEs that focus on their domestic market only have experienced increased administrative costs
without the respective benefits of the use of a single certificate. There has been an increase in charges
and the time needed for the majority of certification procedures.
6.3 Application and implementation
Parameters and barriers that affect the effective implementation of the Directive
A number of parameters have been identified that appear to have an impact on the implementation of
the Directive. Some of them have already been raised in the paragraphs above.
From a negative side, poor quality of market surveillance is an important concern to industry and is an
area where most authorities would recognise that their effort until recently has been insufficient. Only
in few countries have there been tests of the conformity of products placed in the market, usually on
the basis of annual surveillance programmes focusing on specific categories of MIs. Most authorities
concentrate on checking whether the CE+M mark is properly affixed and that the necessary paperwork
is conducted. In some countries even these typical tests are not properly conducted on a periodic basis.
The absence of proper surveillance appears to be the main reason for almost all occasions of unfair
competition reported during our fieldwork. In the case of taximeters (MI-007), even the requirement for
CE+M marking is not properly monitored, arguably favouring local producers whose product does not
fulfil the essential requirements. Similar reports of low levels of surveillance are made in respect of the
authorities in Greece, Bulgaria, Romania and Italy in a wide range of sectors. From their side, the
authorities in most countries mention their limited resources as the underlying reason for the ineffective
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Main findings of the evaluation 6
48
control of the market. However there is no evidence of a particularly problematic issue either in terms
of consumer protection or in terms of the gradual development of a single market.
A second rather problematic area concerns the operation of notified bodies in the assessment of
conformity and the overall certification procedure. On one hand, important parts of the industry and
national authorities claim that notified bodies tend to use WELMEC guidance documents as if they
represent regulations which provide the only possible path for establishing conformity. Industry
representatives referred to occasions when alternative approaches were rejected or considered
unfavourably. This is seen as having a negative role in the development of technological innovation
although there are only a few specific examples provided. On the other hand, notified bodies appear
inconsistent in their operation with important variations in their capacity to carry the necessary tests,
especially those in the new Member States. They are also inconsistent in terms of the content of
certificates issued and the use of evaluation certificates53
.
The notified bodies’ survey suggests that the guidelines and other MID documents are in most respects
clear and cannot be the main source of inconsistencies and variation. However, according to WELMEC
wg11, the MID itself seems to be unclear about which functions of a MI need to be assessed by a
notified body. Also, a few notified bodies referred to unclear elements in the provisions related to some
of the Modules. Furthermore, the provision of WELMEC documents in English only contributes,
according to some NBs, to inconsistencies in their interpretation.
Finally, most industry representatives indicated that the costs and time involved in the certification
process have increased, representing the main cost parameter in the administrative costs of the
Directive. While there have also been cases of reduction of costs and, or time, the majority suggested
that a 15-30% increase in charges is typical. Clearly, the expected benefits from competition among
notified bodies have not yet materialised.
A third problem concerns the unclear definition of what level of modification of a MI constitutes a
repair and what constitutes a new instrument requiring a new certificate. Manufacturers and some
notified bodies state that the regulation is unclear. As a result, there is a tendency to reapply for
certification for even minor changes. This procedure can increase the administrative costs of the
Directive. Examples are changes to software in a taximeter, and cases in the material and dimensional
measurement instruments categories. This issue arises despite the presence of a number of WELMEC
guidance documents that address it in detail and for each category of instrument.
On the positive side, the use of normative documents developed on the basis of OIML
recommendations to provide presumption of conformity appears to have a positive contribution to the
Directive. Only in one sector (MI-005) was there questioning on the appropriateness of the use of
normative documents primarily due to the limited role of industry in their development of international
standards by OIML which is a Treaty Organisation between governments. In all other areas, their use
53 Evaluation certificates concerning components of MIs (the so-called modular approach) are outside of the
Directive (so cannot be issued with NB numbers) and are issued by some labs to show that a specific part is
compatible with the MID requirement and WELMEC has issued relevant guides (which are not referred to from the
Commission website). However some countries (e.g. DE) and the notified bodies do not accept their use on the
grounds that they are not described in the Directive. Companies suggest that this creates additional complications
when moving from one NB to another.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Main findings of the evaluation 6
49
was welcomed because they were already used by manufacturers prior to the MID but also because
they help keep Europe in line with the rest of the world. Such integration helps international trade and
avoids the development of trade barriers. Still, problematic areas do exist and the level of harmonization
does not seem to be complete. The essential requirements are not fully compatible with the OIML
recommendations and this means that there are differences between the normative documents and the
relevant European Standards for utility meters (e.g. MI-002). According to OIML, WELMEC contribution
through the issuing of correspondence tables is positive and is an ongoing process.
More generally, despite problems related to the use of its guidance documents by notified bodies,
WELMEC has a positive contribution towards a more effective implementation of the Directive. The
guidance documents issued by WELMEC - currently close to 6054
- cover the full range of activities and
address the different stakeholders. They serve for the application of conformity assessment procedures
by manufacturers and notified bodies and provide guidance for the various tests. A few industry
stakeholders consider that the number of guidance documents issued has been excessive making them
difficult to follow and possibly confusing. This clearly reflects the broad range of instruments and
conformity assessment procedures to be covered and it should reduce in the coming years.
Furthermore, WELMEC working groups bring together in a coordinated structure experts representing
competent authorities, notified bodies and industry stakeholders. During the four years of the
implementation of the MID, they have supported the identification of issues and problems – technical or
not - related to the implementation of the MID. It has led to a number of proposals based on the
broadest possible consensus.
Finally, the adoption of a 10-year transition period is considered adequate and appropriate by most
industry representatives and authorities. It allows sufficient time for adjustment. However, there is
some evidence to support the fears expressed by a few authorities that the long transition period would
lead manufacturers to rush to certify instruments based on national certificates. The analysis of the data
for the period 2003-2009 from 6 countries (including the three most active- DE, NL and FR) indicate a
clear increase in the pre- MID period up to 2006 followed by a decrease in the 2007-2009 period when
the MID was in force (see figure 5.1). The change was more evident in the case of Netherlands55
but it
was not seen in Germany. The pattern applied in almost all categories of instruments but it was
particularly evident for MI-006 (260 certificates pre-MID against 39 after MID), MI-002 (61 against 2),
MI-003 (326 against 199) and MI-004 (101 against 4). Only dimensional measuring instruments saw an
increase (38 against 44). Such a strategy was not brought up in any of the interviews with manufacturers
in the 10 sectors. However such behaviour could possibly be a result of the increased costs of
certification and the fact the some manufacturers had not been prepared before the entry of the MID
into force. Definite conclusions are premature at this stage and it is a point that needs to be monitored
further.
54 http://www.welmec.org/latest/guides.html
55 Data for 2009 are not available for the Netherlands but, unless there was a sudden increase from the year
before, the overall pattern is not very different.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Main findings of the evaluation 6
50
Source: Data from national authorities
Expected role of the adaptation of the new approach (New Legal Framework - NLF) to the
implementation of the MID
It is expected that the adaptation of the new approach (New Legal Framework) will bring a number of
changes in the implementation of the Directive. On the positive side, competent authorities expect that
the NLF will bring improvements in market surveillance, which, as pointed earlier, is one of the
problems of the implementation of the Directive. Requirements for the development of a surveillance
plan by each Member State are seen by most as a means of ensuring a minimum level of market
surveillance across the EU. It remains unclear however how this will be implemented given that many
competent authorities referred to limited resources as the main underlying issue.
New information exchange obligations posed by the NLF to notified bodies, national authorities and the
Commission should have a positive role in addressing inconsistencies among the 140 notified bodies.
Although WELMEC working groups and the MID working group meetings already represent a forum for
exchange of information there is lack of information exchange between notified bodies, especially in
relation to new and rather small bodies, a number of which do not consider that they have appropriate
0
100
200
300
400
500
600
700
800
900
2003 2004 2005 2006 2007 2008 2009
NL DE CZ AT NO SL FR
Figure 6.1 – Number of type certificates issued before (national and EEC non-MID) and after
(MID) the entry of MID into force (data from seven countries)
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Main findings of the evaluation 6
51
guidance. The working groups should provide an opportunity to increase exchange of information and
practices and help address the most problematic area of the Directive.
On a more negative side, changes in language requirements as a result of the NLF may create
additional costs to manufacturers. The NLF introduces the possibility – although not the requirement -
that Member State authorities may require full documentation in their own language. Such a
requirement is seen by industry as potentially posing important additional costs to companies –
particularly to SMEs. Data concerning costs of translation were limited but companies – primarily in AWI
sector - indicated that in cases where only few instruments are expected to be sold in a single country
they may decide not to enter the national market. Such an eventuality would indicate an effective
barrier to the operation of the single market, diluting the benefits of a single certificate. Still, it should
be noted that such comments came from only a small number of interviewees and the majority of
stakeholders did not consider this as particularly problematic area.
6.4 Strengths and weaknesses of the Directive
Based on the analysis presented, we can summarise the main strengths and weaknesses of the Directive
as it has been implemented so far.
Strengths
• The introduction of the MID has successfully provided the basis for the development of a more
efficiently operating single market on the basis of the use of a single certificate. While this benefit is
not equally experienced across all sectors and countries because of various obstacles – ( most of
which are not related to the implementation of the MID) the majority of companies with a presence
in more than one country indicate that the benefits outweigh the additional administrative costs.
• Overall, the MID has proven a technologically neutral directive and with few minor exceptions, has
not created obstacles to technological innovation. There are issues related to the use of software in
some categories of instruments and of smart meters in utilities, but these are well documented
through WELMEC working groups and efforts are being made to identify appropriate solutions
through guidance documents, standards or amendments.
• The optionality principle, used for around 10% of the total categories of instruments, appears to be
a strong point of the Directive. There is, at least up to now, no evidence to suggest that its use by
Member States has led to unfair competition of a two-tier market in the area legal metrology
instruments. At the same time, the flexibility provided to Member States appears to be an important
factor in achieving agreement in key areas.
• The level of representation of the most affected stakeholders appears appropriate and, while
industry does not have voting rights, WELMEC working groups and the MID working group meetings
are sufficiently open and provide the opportunity for the issues to be properly raised and argued. All
main issues raised by industry during the evaluation are well documented in WELMEC and many
appear high in the priority list to be examined for possible changes and amendments.
• The involvement of WELMEC and the creation of various working groups represent a further strong
point in the implementation of the Directive. It provides a forum for identifying and discussing
various technical issues and other problems. Guidance documents issued are considered by most
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Main findings of the evaluation 6
52
interviewees as useful for the interpretation of both the essential requirements and the conformity
assessment procedures by manufacturers and notified bodies.
Weaknesses
• Market surveillance is one of the key weaknesses of the implementation of the MID so far and it
appears to be the main reason for the development of two tier markets and potential unfair
competition in some sectors and in some Member States. Possibly due to the transition period but
mainly because of limited resources, authorities in the Member States have not given sufficient
priority to market surveillance.
• Inconsistencies on the part of notified bodies in the interpretation of the essential requirements and
the use of WELMEC guidance documents represent a further weakness of the implementation of the
Directive. The 140 bodies notified have varying capacity and follow diverse approaches leading to
variations in the certification process. The costs and time for the certifications process seems to vary
across sectors and Member States.
• The level of market knowledge about the MID appears also relatively limited. The interview
programme indicates that a number of companies – manufacturers and more often importers – are
not properly aware of the applicability and requirements of the Directive. While the respective
associations in the main sectors (utility meters, fuel dispensers, automatic weighing instruments)
are heavily involved and their respective members are informed, this information flow does not
apply to all sectors.. However, the absence of information should be seen in the context of a lower
level of impact and relevance of the Directive in these sectors (e.g. capacity serving measures) and
the low priority attached by the respective trade associations.
• Information exchange among competent authorities and notified bodies in relation to instruments
certified or rejected is also a rather weak point of the implementation of the Directive. According to
most stakeholders it should be improved in order to contribute to more effective market
surveillance.
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Conclusions and recommendations 7
53
In this section we present the main conclusions of the interim evaluation and the respective
recommendations to improve the utility and effectiveness of the Directive.
7.1 Overall conclusions
Overall, the study has found that MID is operating effectively and it has successfully provided the basis
for the development of a single market that operates efficiently through the use of single certificate. In
that respect changes to the main provisions of the MID are not necessary.
However, a number of barriers and inefficiencies are still present. Amongst these are the poor level of
market surveillance, requirements linked to the use of measuring instruments in different countries and
the operation of the notified bodies. Some of these problems can be seen as transitional problems that
should be resolved over time. However, supportive actions, linked with the implementation of the New
Legislative Framework, should be considered and are discussed below.
The effectiveness of the Directive is also limited by a few technical issues (e.g. difference between heavy
and light industry, what constitutes a modifications that requires new certification, the definition of
hard copy) that create confusion and, while not critical, pose problems to notified bodies or increase
costs for manufacturers. These issues are already well documented through WELMEC working groups
that provide the most appropriate forum to identify solutions based either on specific amendments of
the text of the Directive or the issuing of WELMEC guidance documents.
Rather more important for the effectiveness of the Directive is the issue of the adoption of a sub-
assembly approach for fuel dispensers (MI-005) which appears to have negative effects that may
extend beyond the transition period and should, therefore, be addressed. However, it is outside the
scope of this evaluation to propose a specific solution given the technical nature of the issue. WELMEC
provides the appropriate forum for discussing and addressing the issue and this process is already
ongoing. Similarly, in the case of smart meters there is no apparent or broadly accepted solution and a
delay of any decision until further information is collected appears to be the most appropriate action.
In relation to the main issues raised by the European Parliament the analysis indicates that:
• In relation to the optionality principle, there is no evidence that its use has distorted competition
or created two-tier markets of legal metrology instruments. Parallel markets exist in some sectors
as measuring instruments may also be used for non-legal metrology (and thus fall within the scope
of the MID) purposes and their placement in the market is not controlled by national regulation as
far as metrological issues are concerned. Accordingly, parallel markets should be expected to exist
and shall continue in the future but this is not a result of the optionality principle.
• Concerning the role of the Directive in technological innovation, the evaluation did not identify
significant problems concerning the essential requirements of the Directive, which, in most
respects, are technologically neutral. Specific issues exist relating to a number of more or less
technical issues in different sectors (e.g. value of maximum permissible errors, temperature limits in
MI-006, operating conditions in water meters, coverage of smart meters). They have all been well
documented by WELMEC working groups and have been raised in the MID working groups.
Discussions on the appropriate solution on these issues are ongoing in the context of WELMEC.
• The MID decision-making procedures are open to input, commenting and contribution of all
interested stakeholders. There is no evidence that interested parties have been excluded or that
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Conclusions and recommendations 7
54
they did not have the opportunity to raise issues properly. However, not all categories of
instruments have been represented and during the course of the study at least two cases of
associations were identified which indicated that they had no information concerning the operation
of the working groups.
7.2 Recommendations
On the basis of the above conclusions, this evaluation suggests a number of actions that can be
implemented by the European Commission in cooperation with Member States and WELMEC with the
aim of improving the effectiveness and utility of the Directive.
• Enhance the consistency and quality of notified bodies - Notified bodies play a key role in the
implementation of the Directive. There are a few experienced NBs but many have limited resources
and experience. This is one of the reasons for the inconsistencies that affect manufacturers.
WELMEC guides play a supportive role but their interpretation by the notified bodies varies. Thus,
greater sharing of information and experience, including training on the application of conformity
tests should be introduced. There is also a need to clarify issues such as what levels of modification
require additional approval. The New Legislative Framework is expected to provide the legal context
for this type of information and experience exchange. However, the Commission should aim to
promote such activities even before the NLF regulation is actually put in force. In this direction, the
provision of translated versions of the various WELMEC documents should also be examined.
WELMEC most probably does not have the necessary resources for such a task which should be
undertaken at a Member State level.
• Strengthen market surveillance - A problematic area of the implementation of the Directive is the
level of market surveillance. Lack of market surveillance allows non CE+M marked products to be
marketed. Again, the New Legislative Framework regulations are expected to provide the basis for a
more coordinated and planned action by requiring countries to develop and implement surveillance
plans. This probably provides the context for appropriate response to most of the problems.
However, the limited resources and the low priority given to the issue by national authorities
suggest that an improvement in market surveillance may take time to materialise. The Commission’s
role should be to ensure that surveillance plans are developed and implemented by all Member
States, and to press for the necessary resources to be made available. Member States authorities
can make use of the existing guidance document on market surveillance developed by WELMEC. It
would also be helpful to formalise the sharing of results and of experience among the relevant
bodies by means of discussion groups or an online forum. In this regard, it could also be helpful if
Competent Authorities agree to prepare annual plans including their objectives and the resources
to be used, and agree to share these plans with each other and the Commission.
• Increase accessibility of information concerning EC type certificates - Market surveillance also
requires also increased information exchange among authorities and notified bodies concerning
instruments certified or rejected. The certificates database – currently provided by 13 Member
States - represents one of the tools to facilitate exchange of information. The development of a
single database could provide a more effective solution in this respect. However, an initial effort was
not supported by Member States and, in some respects, is not the only possible solution. What is
important is that all Member States publicise the EC type certificates issued and facilitate access to
Interim Evaluation of the Measuring Instruments Directive – Final report Section
Conclusions and recommendations 7
55
this information. Furthermore, a more consistent approach in presenting this information through
the national databases could be agreed to enhance further the access to information.
• Promote a common certificate format - The evaluation findings suggest important variations among
notified bodies in the format of certificates issued for similar categories of instruments. The
Commission should consider, in the context of the dialogue and exchange of experience, the
promotion of a common certificate format to be used by all notified bodies for each category.
WELMEC can serve as the forum for defining a prototype format and its contents.
• Enhance information on the applicability of the MID – One of the findings of the evaluation is that
in a number of countries manufacturers and – even more so – importers are not familiar with the
Directive and its requirements. Member states are primarily responsible for further dissemination of
information through targeted national information campaigns but so far this has not been widely
applied. Renewed efforts by Member States authorities through contacts with key national
partners (sector associations) should be encouraged. In parallel, at the European level the
Commission could initiate a targeted pan-European information campaign with the cooperation of
key stakeholders (European or national industry/trade associations) and articles in the relevant
technical press.
• Invite additional stakeholders in working group meetings – The evaluation identified two industry
stakeholders (FEVE and EGEA) whose members are affected by the implementation of the Directive
that were either not informed of its presence or that had not been previously invited in the
respective working group meetings. The Commission should extent its invitations to these members
and make an additional effort to identify any other stakeholders at the EU level that may be directly
affected by the Directive.
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Interview programme A
56
Trade associations and manufacturers/distributers/users
Organisation Type Status
M-001 water meters
AQUA, European Association of water and heat meters manufacturers Industry
Association
Completed
European Smart Metering Industry Group Industry
Association
Completed
Bruno Janz (PT) Manufacturer Completed
Kamstrup (DK) Manufacturer Completed
Sappel (FR) Manufacturer Contacted
EUREAU, European union of national associations of water suppliers and waste
water services
Industry
Association
Contacted
Apator Powogaz S.A (POL) Manufacturer Contacted
E. Wehrle GmbH (DE) Manufacturer Contacted
Elster Metering limited (DE) Manufacturer Completed
Aquametro (CH) Manufacturer Contacted
Nostrom Manufacturer Contacted
MOM (HU) Manufacturer Contacted
Baylan (TK) Manufacturer Contacted
Sensus (US) Manufacturer Contacted
IWA, International Water Association Industry
Association
Contacted
M-002 gas meters
FACOGAZ, Association of European Gas Meters Manufacturers Industry
Association
Completed
ORES Users Association Completed
Landis+Gyr (CH) Manufacturer Completed
Elster Metering limited (DE) Manufacturer Completed
Sensus (US) Manufacturer Contacted
Itron France Manufacturer /
importer
Contacted
ELGAS s.r.o. Manufacturer Contacted
M-002 active electricity meters
EURELECTRIC/UNIPEDE, Union of the Electricity Industry Industry
Association
Completed
Bruno Janz (PT) Manufacturer Completed
Elster group (DE) Manufacturer /
importer
Completed
Landis+Gyr (CH) Manufacturer Completed
CITEF, Association of European Electricity Meters Manufacturers Industry
Association
Contacted
FIEEC Manufacturer Contacted
Hager Electro GmbH & Co. KG (DE) Manufacturer Contacted
Itron France Manufacturer /
importer
Contacted
Metrima (SW) Manufacturer / Contacted
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Interview programme A
57
Organisation Type Status
importer
M-004 heat meters
AQUA, European Association of water and heat meters manufacturers Trade Association Completed
Lanis+Gyr (CH) Manufacturer Completed
European Smart Metering Industry Group Industry
Association
Completed
Kamstrup (DK) Manufacturer Completed
Allmess GmbH (DE) Manufacturer Completed
EUROHEAT Industry
Association
Contacted
Sontex (UK) Manufacturer Contacted
M-005 petrol pumps
CECOD, European Committee of Manufacturers of Petrol Measuring Systems Industry
Association
Completed
Petrol Pump Manufacturing Association Industry
Association
Completed
Petrotec (PT) Manufacturer Completed
Tokheim (FR) Manufacturer Completed
Scheidt& Bachman (DE) Manufacturer Completed
Hectronics (SE) Manufacturer Completed
Petroleum Equipment Installers and Maintainance Federation (UK + Ireland) Users Completed
Gilbarco (iternational - UK) Manufacturer Completed
Dezidata (DE) Manufacturer Contacted
Hermann-Lummen (DE) Manufacturer Contacted
Sam System (DK) Manufacturer Contacted
K+S (DE) Manufacturer Contacted
Pumptronics (UK) Manufacturer Contacted
M-005 other liquid non-water
Isoil Impianti (IT) Manufacturer Completed
Flaco (DE) Manufacturer Completed
Acram (IT) Manufacturer Completed
Gea Diesel (DE) Manufacturer Contacted
Flow instruments (DE) Manufacturer Contacted
Dezidata (DE) Manufacturer Contacted
Schwarte Milfor (PL) Manufacturer Contacted
Alma (FR) Manufacturer Contacted
Bohlen Doyen (DE) Manufacturer Contacted
Alfons-haar (DE) Manufacturer Contacted
Janksy Manufacturer Contacted
Tasca Tankers (UK) Manufacturer Contacted
SATAM (FR) Manufacturer Contacted
MECI Ltd (UK) Manufacturer Contacted
ENGVA, European Natural Gas Vehicle Association Industry
Association
Contacted
Bartec (UK) Manufacturer Contacted
M-006 AWI
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Interview programme A
58
Organisation Type Status
CECIP, European Committee of Weighing Instruments Manufacturers Industry
Association
Completed
Penko (NL) Manufacturer Completed
Welvaarts weighing systems(NL) Manufacturer Completed
Mettler Toledo (CH) Manufactrurer Completed
Aanderaa Data Instruments AS (NO) Manufacturer Contacted
Teltek (SE) Manufacturer Contacted
Fawag (PL) Manufacturer Contacted
Technipes (IT) Manufacturer Contacted
Mesomatic (DE) Manufacturer Contacted
Feige (DE) Manufacturer Contacted
Bizerba (DE) Manufacturer Contacted
Presia sa (FR) Manufacturer Contacted
Bilansiai (IT) Manufacturer Contacted
Weighwell (UK) Manufactrurer Contacted
MI-007 - Taximeters
Aquila electronics (UK) Manufacturer Completed
Digitax (IT) manufacturer Completed
Hale Electronics Gmbh (AT) Manufacturer Completed
Semel (FI) Manufacturer Completed
Cygnus automotive manufacturer Contacted
Structab (SE) Manufacturer Contacted
M-008 tapes
CEO (European Hand Tools Association) Industry
association
Arranged
Fischer-Darex Outillage (FR) Manufacturer Completed
Toolvizion International (NL) Manufacturer Completed
ENRAF B.V. (NL) Manufacturer Completed
Stanley works (UK) Manufacturer Contacted
STABILA Messgeräte GmbH (DE) Manufacturer Contacted
Bayerische Maßindustrie (DE) Manufacturer Contacted
Top Long industrial Co ltd. (China) Manufacturer Contacted
Lufkin Europe (NL) Manufacturer Contacted
G Borgquist & Co I/S (USA) Manufacturer Contacted
TOVARNA MERIL KOVINE d.d.(SL) Manufacturer Contacted
M-008 capacity serving measures
FEVE – European Container Glass Association Industry
association
Completed
Rona (SK) Manufacturer Contacted
TAJIMA AG (CH) Manufacturer /
importer
Contacted
Mitchell & Cooper (Multinational) Manufacturer /
importer
Completed
Invicta Plastics Ltd (UK) Manufacturer /
importer
Completed
M-009 dimensional measure
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Interview programme A
59
Organisation Type Status
Fischer Instruments (UK) Manufacturer Completed
Vitronic (DE) Manufacturer Completed
Metrie (CZ) Manufacturer Completed
Kabelmat GmbH (DE) Manufacturer Completed
KFM Müller GmbH (DE) Manufacturer Contacted
FARO Techonologies (USA) Manufacturer Contacted
Stanley tools (international) Manufacturer Contacted
Mettler-Toledo Cargoscan AS (Norway) Manufacturer Contacted
Schuller GmbH (DE) Manufacturer Contacted
ALEX Italiana S.r.l. (IT) Manufacturer Contacted
Innovalia (multinational) Manufacturer Contacted
Trumeter (UK) Manufacturer Contacted
SICK (DE) Manufacturer Contacted
Accu-Sort Systems (USA) Manufacturer Contacted
Beta LaserMike Ltd (UK) Manufacturer Contacted
M-010 exhaust gas analyser
EGEA - European Garage Equipment Association Industry
Association
Written
response
Texa (IT) Manufacturer Completed
Robert Bosch (FR) Manufacturer Contacted
Crypton UK) Manufacturer Contacted
Seltec S.rL (IT) Manufacturer Contacted
Tecnotest (IT) Manufacturer Contacted
Brainbee (UK) Manufacturer Contacted
SPX Service Solutions (US) Manufacturer Contacted
DiTEST Fahrzeugdiagnose GMBH (DE) Manufacturer contacted
AVL Manufacturer contacted
Capelec (FR) Manufacturer contacted
FFB Automotive (FR) Manufacturer contacted
Test equipment (NL) Manufacturer contacted
Omitec (UK) Manufacturer contacted
Gunson (UK) Manufacturer contacted
Standard bodies
Organisation Position Status
CEN Standards department – Responsible for metrology Completed
CEN Chairman of Smart Meters Coordination Group Completed
CENELEC Chairman of Technical committee 13 responsible for European standards related
to smart meters Contacted
OIML Assistant director of the OIML secretariat Completed
Competent authorities
Country AUTHORITY Status
AU BEV Completed
BE Ministry of Economics Completed
BG State Agency for Metrology and Technical Supervision (SAMTS) Completed
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Interview programme A
60
Country AUTHORITY Status
CY Ministry of Commerce, Industry and Tourism Completed
CZ UNMZ Completed
DK DFM Completed
EE MKM Declined
FI TUKES Completed
FR Bureau de la métrologie , Ministrere de l'Industrie Completed
DE PTB Completed
GR EIM Completed
HU Mkeh Completed
IR NSAI Completed
IT Ministero dello Sviluppo Economico Written
comments
LV LNMC Completed
LT LVMT Completed
LU ILNAS Completed
MT MSA Completed
NL Minez Completed
PL GUM Declined
PT IPQ Completed
RO BRML Declined
SK Normoff Completed
SL MIRS Completed
ES CEM Completed
SE Swedac Written
comments
UK NMO Completed
UK Department for transport Completed
UK Department for transport Completed
CH Federal office of Metrology Completed
NO Norwegian Metrology Service Completed
IC Metrology Department Declined
WELMEC working groups
WG Area of responsibility status
WG2 Directive implementation Completed
WG5 Metrological supervision Completed
WG7 Software Completed
WG8 General application of MID Completed
WG10 MIs for liquids other than water Completed
WG11 Utility meters Completed
Ad-Hoc WG Information exchange Completed
WELMEC Secretariat Director of WELMEC Completed
Other
Name of association status
NORMAPME – European Office of Crafts, Trades and Small and Medium Enterprises for Completed
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Interview programme A
61
Standardization
BEUC – European Consumers Association /ANEC – European Consumer Voice in Standardization
Declined on
the grounds
of no input
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
References – sources used B
62
Reference documents
- Response of Member States to the Commission letter to competent authorities of 10/07/2009
(CIRCA)
- Position papers of trade associations (CECIP, CEDOC, Eurelectric, Aqua, Facogaz, Marcogaz) on MID
evaluation (CIRCA)
- WELMEC working group proposals for the revision of the MID
- WELMEC guides on MID, accessible from http://www.welmec.org/latest/guides.html
Market research documents
- Multi Utility Meter Report Ed 7 2009 – ABS Research
- European Garage Equipment market study 2008 – Leo-Impact Consulting GMBH
Internet and other sources
• Eurostat, Statistics in focus, Transport, 9/2006 Passenger transport in the European Union,
http://europa.eu/rapid/pressReleasesAction.do?reference=STAT/06/125
• Strategic Analysis of the European Diagnostic Instrumentation Markets,
http://www.researchandmarkets.com/reports/603619/strategic_analysis_of_the_european_diagno
stic
• European Weighing Industry: http://www.cecip.eu/industry.php
• European Glass Containers Association : www.feve.org
• European Hand Tools Association : www.ceo-tools.com
• European Garage Equipment Association: http://www.egea-association.eu/objectives.html
• PRODCOM database - http://epp.eurostat.ec.europa.eu/portal/page/portal/prodcom/introduction
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
MID – PRODCOM correspondence
table
C
63
Type of MI (main groups and subgroups of MI)
Preliminary CN code
Preliminary PRODCOM
code
MI-001: Water Meters 902820 26516350
A. Cold Water Meters:
residential use
commercial & light industrial use
B. Warm Water Meters:
residential use
commercial & light industrial use
MI-002: Gas Meters & Conversion Devices
Gas Meters: 902810 26536330
residential, commerc. & light ind. use
Volume conversion devices: 33205283
residential use
commercial & light industrial use
MI-003: Active Electricity Energy Meters 902830 26516370
Residential
commercial & light industry use
MI-004: Heat Meters 902680 26515283
residential use
commercial & light industry use
MI-005: Measuring Systems for Liquids other
than Water
Fuel dispensers: 84131100 28131105
Liquids
Liquefied gases
Systems on (un)loading ships:
Systems on (un)loading rail:
Systems on (un)loading road tankers:
Systems for refuelling aircraft:
Systems for cryogenic liquids:
Systems for milk:
Systems for liquids: 8471800 269900Z0
Systems for liquefied gases:
MI-006: Automatic Weighing Instr. 8423
Automatic catchweighers: 8423 20 00 29242310
Automatic checkweighers: 84238110
8423 82 10 28293910
Weight labellers: n.a. n.a.
Weight/price labellers: n.a. n.a.
Automatic gravim. filling instruments: 8423 30 00 28293180
Discontinuous totalisers: 8423 89 00 28293180
Continuous totalisers: 8423 30 00 28293180
Rail-weighbridges:
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
MID – PRODCOM correspondence
table
C
64
Type of MI (main groups and subgroups of MI)
Preliminary CN code
Preliminary PRODCOM
code
MI-007: Taximeters 9029 10 00 26516430
MI-008: Material Measures
Material measure of length: 9017 80 10 28293975/28293979
Capacity serving measures:
7013 22/7013 28/7013 33/7013 37
3924 10 00
7013 10 00
23131220
23131240
23131260
23131280
Serving measures:
Transfer measures:
MI-009:Dimensional Measuring Instr. 9031 80 91/9031 80 34/9031 80 38 26516650/26516670
Length measuring instruments:
Area measuring instruments:
Multi-dimensional measuring instr.:
MI-010: Exhaust Gas Analysers n.a. n.a.
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Notified bodies questionnaire
D
65
Survey questionnaire – MID accredited notified bodies
The Centre for Strategy and Evaluation Services carries out on behalf of DG Enterprise and Industry of
the European Commission an independent interim evaluation of the Measuring Instruments Directive
(2004/22/EC).
The evaluation is expected to:
- Assess the utility and effectiveness of the implementation of the Measuring Instruments Directive
(MID);
- Analyse the impacts of the MID on companies and users in the European Union, including trade
barriers that limit the free movement of goods and possibly create obstacles to technological
innovation;
- Assess whether measuring instruments are fit for purpose from the perspective of public interest,
public health, public safety, public order, environmental protection, consumer protection, levying of
taxes and duties and fair trading, where they are legally required by the Member States;
- Compile and assess information on the effective implementation and functioning of the Directive in
terms of its impacts and application; and
- Draw conclusions and recommendations with regard to the scope for the potential improvement of
MID.
The assignment commenced in November 2009 and is due to be completed by June 2010.
Questions
1. Is your organisation:
a. public
b. private body
c. other, please specify : .....
2. For which legal metrology instruments covered by the MID is your organisation designated for?
Please indicate main categories and/or subcategories if applicable.
MI-001: Water Meters □
MI-002: Gas Meters & Conversion Devices □
MI-003: Active Electricity Energy Meters □
MI-004: Heat Meters □
MI-005: Measuring Systems for Liquids other than Water □
MI-006: Automatic Weighing Instr. □
MI-007: Taximeters □
MI-008: Material Measures □
MI-009:Dimensional Measuring Instr. □
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Notified bodies questionnaire
D
66
MI-010: Exhaust Gas Analysers □
3. Which conformity assessment procedures are you designated for? (please check all applicable)
a. A1 □
b. B □
c. C □
d. C1 □
e. D □
f. D1 □
g. E □
h. E1 □
i. F □
j. F1 □
k. G □
l. H □
m. H1 □
4. In relation to the testing of conformity of measuring instruments, how clear do you find the
different MID documents available (standards, the guidance on the normative documents and
guidance documents on the essential requirements)?
EN- Standards OIML normative
documents
MID Guidance on
OIML normative
documents
MID Guidance on
essential
requirements
Very clear □ □ □ □
Clear □ □ □ □
Rather clear □ □ □ □
Unclear □ □ □ □
Very unclear □ □ □ □
Don’t use □ □ □ □
Don’t exist □ □ □ □
No opinion □ □ □ □
5. In relation to the application of the different conformity assessment procedures, how clear do you
find the different MID documents (standards, the guidance on the normative documents and
guidance documents on the essential requirements) to be?
EN-Standards on conformity
assessment
MID Guidance on conformity
assessment procedures
Very clear □ □
Clear □ □
Rather clear □ □
Unclear □ □
Very unclear □ □
Don’t use □ □
No opinion □ □
Interim Evaluation of the Measuring Instruments Directive – Final report Appendix
Notified bodies questionnaire
D
67
6. Based on your experience so far, do you think that the essential requirements of the MID allow
technological innovation by manufacturers? (YES/NO, please explain- text box).
7. Please, refer to any advantages/problems you have experienced in relation to the implementation
of the Directive. (text box)
8. What has been the total number of type examinations, quality system approvals and verifications
you have performed in the last 3 years? If possible, indicate by each type of measuring instrument. If
possible, please indicate also the average cost for each category of instrument.
EC type
examinations
Quality
system
approvals
Verifications Average
cost
MI-001: Water Meters
MI-002: Gas Meters & Conversion Devices
MI-003: Active Electricity Energy Meters
MI-004: Heat Meters
MI-005: Measuring Systems for Liquids other than
Water
MI-006: Automatic Weighing Instr.
MI-007: Taximeters
MI-008: Material Measures
MI-009:Dimensional Measuring Instr.
MI-010: Exhaust Gas Analysers
9. Would you willing to be contacted by CSES for a brief further discussion on the above issues?
(YES/NO) If yes, please provide contact details.
Thank you very much for your cooperation.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
68
MI-
00
1 –
Wa
ter
me
ters
56
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/
ex
am
ple
s
Ov
era
ll e
xpe
rie
nce
fro
m t
he
imp
lem
en
tati
on
of
the
Dir
ect
ive
Ov
era
ll,
bo
th A
QU
A a
nd
th
e i
nd
ivid
ua
l m
an
ufa
ctu
rers
su
gg
est
ed
a p
osi
tiv
e
exp
eri
en
ce f
rom
th
e i
mp
lem
en
tati
on
of
the
MID
un
til n
ow
. T
he
Dir
ect
ive
ha
s b
ee
n
bu
ilt
on
Dir
ect
ive
75
/33
/EE
C,
wh
ich
alr
ea
dy
in
clu
de
d a
nu
mb
er
of
leg
al
me
tro
log
y
asp
ect
s a
nd
, a
s a
re
sult
, si
mil
ar
typ
es
of
ap
pro
va
ls h
ad
to
be
ma
de
pri
or
to t
he
MID
. T
he
ne
w D
ire
ctiv
e d
id n
ot
bri
ng
ma
jor
cha
ng
es.
On
to
p o
f th
at,
th
e i
nd
ust
ry
con
sid
ere
d t
ha
t th
e p
art
icip
ati
on
in
th
e w
ork
ing
gro
up
of
MIs
(e
xte
nd
ed
sh
ari
ng
of
exp
eri
en
ce a
nd
re
al
“ma
na
ge
me
nt”
of
MID
) w
as
a p
osi
tiv
e i
mp
rov
em
en
t.
Th
e o
nly
ne
ga
tiv
e p
oin
t ca
me
fro
m t
he
Da
nis
h C
A w
hic
h s
ug
ge
ste
d t
ha
t M
ID i
s in
con
tra
dic
tio
n w
ith
th
e D
ire
ctiv
e o
n e
ne
rgy
en
d-u
se e
ffic
ien
cy a
nd
th
at
the
re i
s p
oo
r
qu
ali
ty o
f th
e o
f cl
ass
A m
ete
rs c
ov
ere
d b
y t
he
MID
.
An
ne
x M
I-0
01
of
the
MID
sta
tes
tha
t a
re
ad
ing
is
ne
cess
ary
in
th
e
inst
rum
en
ts.
In
ord
er
to
en
sure
co
nsu
me
r
pro
tect
ion
, a
nd
be
cau
se o
f
the
gro
win
g c
om
ple
xity
of
wa
ter
pri
cin
g,
the
Da
nis
h C
A
be
lie
ve
s th
at
info
rma
tio
n
such
as
vo
lum
e,
pri
ce,
tim
e
of
use
etc
sh
ou
ld a
lso
be
dis
pla
ye
d.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
On
e l
arg
e m
an
ufa
ctu
rer
an
d t
he
tra
de
ass
oci
ati
on
(A
QU
A)
acc
ep
ted
th
at
the
MID
ha
s h
elp
ed
de
ve
lop
a m
ore
eff
ect
ive
sin
gle
ma
rke
t th
an
un
de
r th
e p
rev
iou
s re
gim
e.
Th
ey
me
nti
on
ed
th
at
the
re h
av
e b
ee
n c
lea
r b
en
efi
ts f
rom
th
e n
ece
ssit
y f
or
typ
e
ap
pro
va
l in
on
ly o
ne
co
un
try
.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Th
e m
an
ufa
ctu
rers
an
d t
rad
e a
sso
cia
tio
n d
o n
ot
be
lie
ve
th
at
the
MID
ha
mp
ers
inn
ov
ati
on
wit
h t
he
no
tab
le e
xce
pti
on
of
the
iss
ue
of
sma
rt m
ete
rin
g (
ad
dre
ss
late
r).
Op
tio
na
lity
- Is
it
use
d i
n t
he
se
cto
r
(ho
w m
an
y M
S a
nd
wh
y)
- Is
th
ere
ev
ide
nce
of
two
-tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
co
mp
eti
tio
n
2 c
ou
ntr
ies
use
it
for
resi
de
nti
al
– 4
fo
r li
gh
t in
du
stry
. R
ea
son
s st
ate
d w
as
the
ab
sen
ce f
rom
th
e m
ark
et
an
d l
ack
of
pu
bli
c p
oli
cy p
rob
lem
Acc
ord
ing
to
AC
QU
A,
pro
fess
ion
als
in
th
e s
ect
or
are
no
t v
ery
fa
mil
iar
wit
h t
he
op
tio
na
lity
pri
nci
ple
. A
tw
o-t
ier
ma
rke
t, o
f tr
ad
e b
arr
iers
an
d u
nfa
ir c
om
pe
titi
on
cou
ld b
e a
re
sult
bu
t A
QU
A d
oe
s n
ot
ha
ve
an
y d
ata
or
ev
ide
nce
to
su
pp
ort
th
is.
Ma
nu
fact
ure
rs p
oin
t a
lso
to
th
e f
act
th
at
ov
er
2/3
rds
of
wa
ter
me
ters
pu
rch
ase
d i
n
the
EU
are
pu
rch
ase
d b
y p
rofe
ssio
na
ls o
r d
ire
ctly
by
th
e w
ate
r d
istr
ibu
tors
. T
he
y
ha
ve
a v
est
ed
in
tere
st i
n h
av
ing
re
lia
ble
me
teri
ng
sy
ste
ms
ba
sed
on
MID
cert
ific
ati
on
.
56 B
ase
d o
n i
nte
rvie
w w
ith
a r
ep
rese
nta
tiv
e o
f th
e t
wo
tra
de
ass
oci
ati
on
s A
CQ
UA
an
d E
SM
IG,
an
d t
hre
e l
arg
e m
an
ufa
ctu
rers
Els
ter
(DE
), B
run
o J
an
z (P
T),
Ka
mst
rup
(D
K).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
69
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/
ex
am
ple
s
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
Th
ere
is
no
co
nce
rn a
bo
ut
con
sum
er
pro
tect
ion
iss
ue
s b
ase
d o
n o
pti
on
ali
ty.
Co
nsu
me
rs d
o n
ot
ge
ne
rall
y p
urc
ha
se t
he
me
ters
th
em
selv
es.
Th
ose
are
in
sta
lle
d
by
th
e d
istr
ibu
tors
an
d t
he
y h
av
e a
ve
ste
d i
nte
rest
in
ha
vin
g r
eli
ab
le m
ete
rin
g
syst
em
s b
ase
d o
n M
ID c
ert
ific
ati
on
.
Ho
w h
av
e a
dm
inis
tra
tiv
e a
nd
oth
er
cost
s in
cre
ase
d /
red
uce
d
for
firm
s a
nd
fo
r a
dm
inis
tra
tio
ns
Ov
era
ll,
ma
nu
fact
ure
rs b
eli
eve
th
at
the
im
ple
me
nta
tio
n o
f th
e D
ire
ctiv
e h
as
no
t
cha
ng
ed
th
e c
ost
s a
nd
ad
min
istr
ati
ve
bu
rde
ns.
Th
e D
ire
ctiv
e d
oe
s n
ot
rad
ica
lly
cha
ng
e t
he
pre
vio
us
reg
ime
, it
ad
ap
ts a
nd
ha
rmo
nis
es
it b
ase
d o
n e
xist
ing
ru
les
Ho
we
ve
r, a
cco
rdin
g t
o o
ne
CA
, th
ere
wa
s a
n e
ffo
rt b
y s
om
e c
om
pa
nie
s to
ha
ve
pro
du
cts
tha
t h
ad
alr
ea
dy
be
en
ap
pro
ve
d u
nd
er
the
old
Dir
ect
ive
ap
pro
ve
d u
nd
er
the
MID
, w
hic
h m
igh
t h
av
e i
ncr
ea
sed
co
sts
a l
ittl
e.
A C
A t
ha
t d
id n
ot
wa
nt
to b
e
dis
clo
sed
re
ferr
ed
to
an
an
ecd
ota
l e
vid
en
ce o
f m
ete
rs
ap
pro
ve
d u
nd
er
the
old
reg
ime
be
ing
su
bm
itte
d a
ga
in
for
ap
pro
va
l u
nd
er
the
MID
.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Ve
ry s
ati
sfa
cto
ry,
the
wg
MI
ha
s b
ee
n o
ne
of
the
mo
st w
elc
om
e a
spe
cts
of
MID
.
Tw
o m
an
ufa
ctu
rers
an
d a
tra
de
ass
oci
ati
on
un
de
rlin
e t
he
im
po
rta
nce
of
the
wo
rkin
g g
rou
ps
to r
ed
uce
th
e t
ime
be
twe
en
th
e i
mp
lem
en
tati
on
of
the
Dir
ect
ive
an
d t
he
sm
oo
th u
nd
ers
tan
din
g a
nd
ru
nn
ing
of
the
op
era
tio
ns.
Imp
act
/iss
ue
s fo
r S
ME
s (r
efe
r to
the
ext
en
t th
at
SM
Es
ma
y f
ace
pa
rtic
ula
r p
rob
lem
s in
com
pa
riso
n t
o l
arg
e f
irm
s)
Giv
en
th
e d
om
ina
nce
of
larg
e s
ize
fir
ms
in t
he
se
cto
r th
is i
s se
en
as
a m
ino
r is
sue
, if
it a
pp
lie
s a
t a
ll.
Th
e S
ME
s su
rve
y (
incl
ud
ing
91
SM
Es
act
ivit
y i
n t
he
se
cto
r) d
id n
ot
ind
ica
te p
rob
lem
s re
late
d t
o t
he
co
nfo
rmit
y p
roce
du
res
an
d l
ess
th
an
20
% r
efe
rre
d
to t
he
pre
sen
ce o
f a
ny
ba
rrie
rs t
o t
rad
e
Pa
ram
ete
rs t
ha
t a
ffe
ct t
he
im
ple
me
nta
tio
n o
f th
e D
ire
ctiv
e
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts (
incl
.
role
of
WE
LME
C)
WE
LME
C i
s se
en
as
by
all
inte
rvie
we
es
as
ext
rem
ely
use
ful
for
the
co
ord
ina
tio
n
be
twe
en
No
tifi
ed
Bo
die
s a
nd
Na
tio
na
l O
rga
nis
ati
on
s. W
ELM
EC
gu
ide
lin
es
ha
ve
be
en
use
ful
for
ha
rmo
nis
ati
on
an
d f
or
the
co
mm
on
in
terp
reta
tio
n o
f th
e M
ID.
Th
e l
ev
el
of
sta
nd
ard
s is
suin
g h
as
be
en
of
hig
he
r le
ve
l si
nce
th
e i
ntr
od
uct
ion
of
the
MID
.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Ma
nu
fact
ure
rs d
id n
ot
ha
ve
an
yth
ing
to
co
mm
en
t –
eit
he
r p
osi
tiv
e o
r n
eg
ati
ve
- o
n
the
im
ple
me
nta
tio
n b
y n
oti
fie
d b
od
ies.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
It i
s th
e m
ain
asp
ect
th
at
all
in
terv
iew
ee
s co
nsi
de
red
as
mis
sin
g f
rom
th
e M
ID.
Th
ey
exp
ect
th
at
som
e v
ery
lig
ht
ma
rke
t su
rve
illa
nce
wil
l b
e i
ntr
od
uce
d b
y t
he
Ne
w
Leg
isla
tiv
e F
ram
ew
ork
(N
LF).
•
Tra
nsi
tio
n p
eri
od
(st
ate
d
be
ne
fits
/iss
ue
s)
All
ma
nu
fact
ure
rs a
gre
ed
th
at
10
ye
ars
is
an
ap
pro
pri
ate
tra
nsi
tio
n p
eri
od
.
Oth
er
Acc
ord
ing
to
AC
QU
A,
the
re s
ho
uld
be
ch
an
ge
s in
th
e e
sse
nti
al
req
uir
em
en
ts r
ate
d
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
70
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/
ex
am
ple
s
op
era
tin
g c
on
dit
ion
sh
ou
ld b
e i
mp
rov
ed
. T
he
co
nce
rn i
s th
at
the
cu
rre
nt
lev
el
all
ow
ed
by
th
e M
ID i
s n
ot
stri
ng
en
t e
no
ug
h a
nd
po
ten
tia
lly
all
ow
s lo
we
r q
ua
lity
me
ters
on
th
e m
ark
et.
(C
urr
en
tly
a r
ati
o o
f 1
0 b
etw
ee
n Q
3/Q
1 i
s a
llo
we
d.
AC
QU
A
wo
uld
lik
e t
o s
ee
a r
ati
o o
f a
t le
ast
40
co
me
in
to f
orc
e a
nd
im
po
se a
fa
r lo
we
r Q
1)
MI-
00
2 –
Ga
s m
ete
rs5
7
Issu
es
F
ind
ing
s (s
o f
ar)
E
vid
en
ce/d
ata
/oth
er
info
/ e
xa
mp
les
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
Ov
era
ll,
the
in
du
stry
co
nsi
de
red
th
at
MID
’s m
ain
str
en
gth
s h
av
e b
ee
n t
he
red
uct
ion
of
rest
rict
ion
s to
fre
e t
rad
e,
the
sp
ace
all
ow
ing
fo
r te
chn
olo
gic
al
inn
ov
ati
on
an
d t
he
op
tio
na
lity
cla
use
.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
Ov
era
ll,
all
ma
nu
fact
ure
rs s
tate
d s
ati
sfa
ctio
n t
ha
t th
e M
ID h
as
he
lpe
d d
ev
elo
p a
n
eff
icie
nt
sin
gle
ma
rke
t.
On
e b
arr
ier
to t
rad
e s
tate
d b
y W
ELM
EC
wg
10
wa
s th
e a
bse
nce
of
a c
om
mo
n
de
fin
itio
n o
f li
gh
t a
nd
he
av
y in
du
stry
. In
th
e c
ase
of
ga
s m
ete
rs,
in D
E t
he
thre
sho
ld i
s 9
,00
0 t
ime
s h
igh
er
tha
n i
n N
L T
he
Hu
ng
ari
an
no
tifi
ed
bo
dy
exp
ress
ed
the
sa
me
co
nce
rn.
Acc
ord
ing
to
Ma
rco
ga
z, A
n i
mp
ort
an
t
be
ne
fit
for
use
rs i
n t
he
uti
lity
se
cto
r is
the
op
po
rtu
nit
y t
o c
on
du
ct p
ub
lic
pro
cure
me
nt
wit
h r
efe
ren
ce t
o M
ID
req
uir
em
en
ts a
nd
no
t fo
r se
pa
rate
na
tio
na
l ce
rtif
ica
tes.
Th
is i
ncr
ea
ses
cho
ice
an
d h
as
the
po
ten
tia
l to
re
du
ce
pri
ce d
ue
to
in
cre
ase
d c
om
pe
titi
on
.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Th
ere
is
no
co
mm
on
vie
w o
n t
he
ro
le o
f th
e M
ID o
n t
his
asp
ect
.
Tw
o m
an
ufa
ctu
rers
be
lie
ve
th
at
de
tail
s in
th
e M
ID h
am
pe
r in
no
va
tio
n a
s th
e
fun
da
me
nta
l p
hil
oso
ph
y o
f th
e D
ire
ctiv
e t
o b
e “
tech
no
log
ica
lly
in
de
pe
nd
en
t” h
as
no
t b
ee
n f
oll
ow
ed
th
rou
gh
ou
t. O
ne
pro
ble
m i
de
nti
fie
d i
s th
e d
isp
lay
on
inst
rum
en
ts,
wit
h o
nly
th
e v
olu
me
or
ma
ss o
f g
as
dis
pla
ye
d.
Ho
we
ve
r, M
arc
og
az
con
sid
ere
d t
ha
t th
e D
ire
ctiv
e i
s te
chn
olo
gy
ne
utr
al.
On
e
ma
nu
fact
ure
r a
lso
su
pp
ort
ed
th
is v
iew
su
gg
est
ing
th
at
the
re a
re a
llo
we
d t
o
intr
od
uce
in
no
va
tiv
e s
olu
tio
ns
wit
ho
ut
ne
ed
to
mo
dif
y t
he
MID
. T
he
sa
me
ma
nu
fact
ure
r a
lso
me
nti
on
ed
th
e f
act
th
at
as
the
re i
s n
o o
bli
ga
tio
n t
o s
tan
da
rds,
Acc
ord
ing
to
on
e c
om
pa
ny
th
e M
ID
on
ly a
llo
ws
for
me
ters
dis
pla
yin
g t
he
vo
lum
e o
r th
e m
ass
of
ga
s; i
t d
oe
s n
ot
all
ow
fo
r th
e m
ete
rs d
isp
layi
ng
en
erg
y
or
mo
ne
tary
me
teri
ng
. If
su
ch a
solu
tio
n i
s e
ve
r to
be
in
ve
nte
d,
it w
ill
no
t fa
ll u
nd
er
the
MID
.
57 B
ase
d o
n i
nte
rvie
ws
wit
h r
ep
rese
nta
tiv
es
of
thre
e t
rad
e a
sso
cia
tio
ns
(FA
CO
GA
Z,M
arc
og
az,
OR
ES
) a
nd
th
ree
ma
nu
fact
ure
rs,
Lan
dis
+G
yr
(CH
), E
lste
r (D
E),
Ka
mst
rup
(D
K).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
71
the
re i
s g
rea
ter
fre
ed
om
in
th
e d
ev
elo
pm
en
t o
f fu
ture
te
chn
olo
gie
s.
Ho
we
ve
r, i
t is
als
o s
ug
ge
ste
d b
y a
ll in
terv
iew
ee
s th
at
the
MID
do
es
no
t ca
ter
for
po
ssib
le f
utu
re i
nn
ov
ati
on
th
at
wo
uld
fa
ll o
uts
ide
of
the
Dir
ect
ive
. A
do
cum
en
ted
issu
e c
on
cern
s sm
art
me
ters
. S
ma
rt m
ete
rs a
re e
xpe
cte
d t
o i
ncr
ea
se i
n t
he
fu
ture
be
cau
se o
f e
nv
iro
nm
en
tal
an
d e
ne
rgy
eff
icie
ncy
re
gu
lati
on
. A
nu
mb
er
of
CA
s
pro
po
sed
ch
an
ge
s to
th
e D
ire
ctiv
e t
o t
ak
e i
nto
co
nsi
de
rati
on
sm
art
me
ters
.
Ho
we
ve
r, t
he
in
du
stry
– t
hro
ug
h M
arc
og
az
- is
no
t in
fa
vo
ur
of
an
y c
ha
ng
es
of
the
Dir
ect
ive
at
this
po
int
as
the
re i
s n
ee
d t
o b
uil
d e
xpe
rie
nce
an
d t
he
te
chn
ica
l is
sue
s
rela
ted
to
re
mo
te r
ea
din
g a
nd
tw
o-w
ay
co
mm
un
ica
tio
n t
ha
t a
re s
till
un
cle
ar.
Op
tio
na
lity
- Is
it
use
d i
n t
he
se
cto
r?
- Is
th
ere
ev
ide
nce
of
two
-
tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
com
pe
titi
on
Op
tio
na
lity
no
t u
sed
in
ga
s m
ete
rs (
2 c
ou
ntr
ies)
an
d n
o is
sue
s in
re
lati
on
to
an
y o
f
the
qu
est
ion
s w
ere
re
po
rte
d.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
No
ev
ide
nce
of
the
ro
le o
f o
pti
on
ali
ty id
en
tifi
ed
. M
ore
ge
ne
ral
MA
RC
OG
AZ
sug
ge
sts
tha
t th
ere
ha
s b
ee
n i
mp
rov
em
en
t a
s in
so
me
co
un
trie
s w
ith
lo
we
r
sta
nd
ard
s th
e M
ID d
id p
ush
sta
nd
ard
s u
p a
nd
be
ne
fite
d c
on
sum
ers
/use
rs.
Tw
o
ma
nu
fact
ure
rs e
mp
ha
sise
d t
ha
t a
s fo
r o
the
r u
tili
ty m
ete
rs,
this
is n
ot
see
n a
s a
pro
ble
m a
s m
ete
rs a
re g
en
era
lly
pu
rch
ase
d i
n b
ulk
by
th
e g
as
sup
pli
ers
th
at
ha
ve
an
in
tere
st i
n h
av
ing
eff
icie
nt
me
ters
.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
No
sig
nif
ica
nt
cha
ng
e m
en
tio
ne
d s
ince
th
e i
ntr
od
uct
ion
of
the
MID
.
On
e l
arg
e n
ati
on
al
com
pa
ny
sta
ted
tha
t th
e m
ain
ad
min
istr
ati
ve
co
sts
com
e f
rom
th
e p
eri
od
ic a
ud
its
tha
t th
e
NB
is
carr
yin
g o
ut
for
mo
du
le D
ass
ess
me
nt,
wh
ich
did
no
t e
xist
in
th
e
pre
vio
us
leg
al
con
text
. T
he
y d
o
un
de
rlin
e t
ha
t th
ey
co
uld
ch
an
ge
th
e
mo
du
le n
ee
de
d f
or
Ty
pe
Ap
pro
va
l in
wh
ich
ca
se t
he
y w
ou
ld n
ot
ha
ve
to
be
au
dit
ed
an
d t
he
co
st o
f co
nfo
rmit
y
wo
uld
dro
p b
elo
w t
he
le
ve
ls o
f th
e
pre
vio
us
reg
ime
.
Re
pre
sen
tati
on
in
th
e
It i
s co
nsi
de
red
im
po
rta
nt
tha
t th
e i
nd
ust
ry is
re
pre
sen
ted
an
d i
nv
olv
ed
in
th
e
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
72
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
wg
MI
me
eti
ng
s. M
arc
og
az
con
sid
ers
its
elf
ext
en
siv
ely
in
vo
lve
d w
ith
no
pro
ble
ms.
On
e l
arg
e m
an
ufa
ctu
rer
als
o u
nd
erl
ine
d t
he
im
po
rta
nce
of
the
wo
rkin
g g
rou
ps
to
red
uce
th
e t
ime
be
twe
en
th
e i
mp
lem
en
tati
on
of
the
Dir
ect
ive
an
d t
he
sm
oo
th
un
de
rsta
nd
ing
an
d r
un
nin
g o
f th
e o
pe
rati
on
s.
Imp
act
on
SM
Es
M
an
ufa
ctu
rer
sta
ted
th
at
SM
Es
we
re n
ot
pre
sen
t o
n t
he
ma
rke
t a
nd
as
a r
esu
lt,
the
y a
re n
ot
pa
rtic
ula
rly
aff
ect
ed
. (T
he
y w
ere
no
t b
efo
re t
he
in
tro
du
ctio
n o
f th
e
MID
eit
he
r).
Th
e S
ME
su
rve
y r
esu
lts
ind
ica
te t
ha
t le
ss t
ha
t 2
5%
of
the
fir
ms
in
sect
or
exp
eri
en
ced
ba
rrie
rs t
o t
rad
e a
nd
on
ly o
ne
th
at
con
form
ity
ass
ess
me
nt
pro
ced
ure
s a
re p
rob
lem
ati
c.
Pa
ram
ete
rs t
ha
t a
ffe
ct t
he
im
ple
me
nta
tio
n o
f th
e D
ire
ctiv
e
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts (
incl
.
role
of
WE
LME
C)
Th
e i
ssu
ing
of
sta
nd
ard
s is
se
en
as
on
e o
f th
e k
ey
po
siti
ve
asp
ect
s o
f th
e
ne
w a
pp
roa
ch.
Th
e g
uid
eli
ne
s is
sue
d b
y W
ELM
EC
are
co
nsi
de
red
im
po
rta
nt
reg
ard
ing
th
e l
on
g-t
erm
exp
eri
en
ces
of
me
tro
log
ica
l a
uth
ori
tie
s. H
ow
ev
er,
Ma
rco
ga
z p
rop
ose
d t
ha
t th
e o
pe
rati
on
an
d c
on
sist
en
cy o
f th
e n
oti
fie
d
bo
die
s is
no
t sa
tisf
act
ory
. M
arc
og
az
sug
ge
ste
d a
lso
th
at
the
use
of
OIM
L
no
rma
tiv
e d
ocs
is
stil
l n
ot
10
0%
sa
tisf
act
ory
as
the
re a
rea
s w
he
re t
he
re i
s
no
ha
rmo
niz
ati
on
wit
h E
uro
pe
an
sta
nd
ard
s.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Tw
o l
arg
e m
an
ufa
ctu
rers
un
de
rlin
ed
th
at
the
MID
’s m
ain
we
ak
ne
ss i
s th
e
va
ryin
g l
ev
el
of
qu
ali
ty o
f th
e n
oti
fie
d b
od
ies,
in
te
rms
of
exp
eri
en
ce,
kn
ow
led
ge
an
d c
ust
om
er
ori
en
tati
on
an
d M
arc
og
az
wa
s a
lso
sce
pti
cal
of
the
qu
ali
ty o
f th
e t
est
s b
y s
om
e N
Bs.
On
e m
an
ufa
ctu
rer
refe
rre
d t
o a
pro
ble
m t
ha
t st
ill
ha
s n
ot
be
en
re
solv
ed
re
ga
rdin
g d
iffe
ren
t in
terp
reta
tio
ns
of
the
ess
en
tia
l re
qu
ire
me
nts
an
d c
on
form
ity
pro
ced
ure
s b
y t
he
No
tifi
ed
Bo
die
s.
On
e c
om
pa
ny
re
po
rte
d a
pro
ble
m w
ith
a
Ge
rma
n n
oti
fie
d b
od
y n
ot
acc
ep
tin
g o
ne
of
the
ir p
rod
uct
s th
at
ha
d b
ee
n a
cce
pte
d b
y
ME
TA
S i
n 2
00
8.
Th
e i
ssu
e w
as
reg
ard
ing
th
e
ma
xim
um
pe
rmis
sib
le e
rro
r.
Th
e i
ssu
e h
as
be
en
ta
ke
n b
y M
ET
AS
to
WE
LME
C a
nd
ha
s
stil
l n
ot
be
en
re
solv
ed
.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
All
th
e m
an
ufa
ctu
rers
we
ha
ve
sp
ok
en
to
sta
ted
th
at
the
re i
s a
cle
ar
ne
ed
for
furt
he
r a
ctio
n i
n t
erm
s o
f m
ark
et
surv
eil
lan
ce.
Ma
rco
ga
z co
nsi
de
rs t
ha
t
surv
eil
lan
ce i
s ra
the
r li
mit
ed
alt
ho
ug
h g
rad
ua
lly
in
cre
asi
ng
. R
eg
ula
tio
n
20
07
/29
(N
LF)
tha
t ca
me
in
to f
orc
e i
n J
an
ua
ry 2
01
0 i
s e
xpe
cte
d t
o h
av
e
po
siti
ve
im
pa
cts
on
ma
rke
t su
rve
illa
nce
.
•
Tra
nsi
tio
n p
eri
od
(be
ne
fits
/iss
ue
s)
10
ye
ars
wa
s co
nsi
de
red
an
ap
pro
pri
ate
tra
nsi
tio
n p
eri
od
an
d n
on
e o
f th
e
ma
nu
fact
ure
rs e
xpre
sse
d a
ny
pro
ble
ms/
con
cern
s w
ith
th
e t
ran
siti
on
pe
rio
d.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
73
MI-
00
3 –
Ele
ctri
city
me
ters
58
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
Ma
nu
fact
ure
rs a
nd
tra
de
ass
oci
ati
on
are
ple
ase
d w
ith
th
e M
ID a
nd
se
e i
t a
s a
n
imp
rov
em
en
t o
n t
he
pre
vio
us
reg
ime
. H
ow
ev
er,
ma
nu
fact
ure
rs s
till
re
fer
to t
he
fa
ct
tha
t m
an
y o
f th
e b
en
efi
ts o
f th
e M
ID a
re n
ot
ev
ide
nt
as
the
re a
re m
an
y n
ati
on
al
spe
cifi
cati
on
s st
ill
cov
eri
ng
fu
nct
ion
ali
ty a
nd
na
tio
na
l a
pp
rov
als
th
at
are
re
qu
ire
d.
As
a r
esu
lt t
ha
t ‘O
ld a
nd
ne
w’
syst
em
s a
re r
un
nin
g i
n p
ara
lle
l th
ere
fore
in
cre
ase
wo
rklo
ad
.
An
oth
er
issu
e r
efe
rre
d t
o b
y a
tra
de
ass
oci
ati
on
is
the
fa
ct t
ha
t t
he
MID
all
ow
s
Me
mb
er
Sta
tes
to i
mp
ose
me
tro
log
ica
l co
ntr
ol
of
me
asu
rem
en
t u
sin
g d
iffe
ren
t
Cla
sse
s o
f m
ete
r fo
r re
sid
en
tia
l a
nd
co
mm
erc
ial
/ li
gh
t in
du
stri
al
use
. I
t d
oe
s n
ot
ho
we
ve
r d
efi
ne
bo
un
da
rie
s b
etw
ee
n t
he
tw
o t
yp
es
of
me
ters
. O
ne
la
rge
ma
nu
fact
ure
r st
ate
d t
ha
t th
e M
ID’s
co
nfo
rmit
y a
sse
ssm
en
t a
nd
ve
rifi
cati
on
pro
ced
ure
s w
ere
he
lpfu
l in
ste
pp
ing
up
th
e q
ua
lity
ass
ura
nce
of
the
ir p
rod
uct
s
Slo
ve
nia
n C
om
pe
ten
t A
uth
ori
ty
sta
ted
th
at
ma
nu
fact
ure
rs o
f
ele
ctri
city
me
ters
are
in
ge
ne
ral
ple
ase
d.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
An
eff
icie
nt
sin
gle
ma
rke
t is
sti
ll n
ot
pre
sen
t a
cco
rdin
g t
o a
ll i
nte
rvie
we
es.
Th
ey
refe
rre
d t
o t
rad
e b
arr
iers
by
th
e d
iffe
ren
t tr
ea
tme
nt
of
act
ive
re
act
ive
me
asu
rem
en
t.
As
the
tw
o i
nst
rum
en
ts p
erf
orm
me
teri
ng
ta
sks,
on
ly i
ncl
ud
ing
on
e i
n t
he
MID
do
es
no
t h
elp
in
th
e d
ev
elo
pm
en
t o
n a
n e
ffic
ien
t si
ng
le m
ark
et.
Th
ere
are
dif
fere
nt
sev
eri
ty l
ev
els
of
the
te
sts
use
d b
y t
he
no
tifi
ed
bo
die
s th
at
are
cou
ntr
y-d
ep
en
de
nt
lea
din
g t
o d
iffe
ren
t q
ua
lity
lev
els
.
Fu
rth
erm
ore
, a
ctiv
e e
lect
rici
ty m
ete
rs o
fte
n i
ncl
ud
e c
om
po
ne
nts
th
at
are
no
t co
ve
red
by
th
e M
ID a
nd
are
su
bje
ct t
o n
ati
on
al
ap
pro
va
ls.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Acc
ord
ing
to
so
me
CA
s (N
L, A
T)
the
MID
on
ly c
ov
ers
a m
inim
al
pa
rt o
f m
od
ern
ele
ctri
city
me
ter.
An
y “
inn
ov
ati
ve
” fe
atu
re i
s b
ey
on
d s
cop
e o
f M
ID a
nd
th
e D
ire
ctiv
e
ha
s n
o i
nfl
ue
nce
on
th
is.
An
oth
er
issu
e s
tate
d (
by
wh
om
?)
con
cern
ed
th
e s
ma
rt m
ete
rs–
th
is h
am
pe
rs
inn
ov
ati
on
.
58 B
ase
d o
n i
nte
rvie
ws
wit
h r
ep
rese
nta
tiv
es
of
two
tra
de
ass
oci
ati
on
(E
ure
lect
ric,
ES
MIG
) a
nd
th
ree
ma
nu
fact
ure
rs :
Bru
no
Ja
nz
(PT
), L
an
dis
+G
yr
(CH
),
Els
ter(
DE
)
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
74
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Op
tio
na
lity
- Is
it
use
d i
n t
he
se
cto
r
- Is
th
ere
ev
ide
nce
of
two
-
tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
com
pe
titi
on
Op
tio
na
lity
is n
ot
use
d i
n t
he
se
cto
r (t
he
on
ly e
xce
pti
on
is
Ma
lta
as
the
re a
re n
o
ele
ctri
city
me
ters
in
th
e c
ou
ntr
y)
Th
ere
we
re n
o c
on
cern
s ra
ise
d b
y m
an
ufa
ctu
rers
co
nce
rnin
g u
nfa
ir c
om
pe
titi
on
an
d
du
e t
o o
pti
on
ali
ty a
nd
no
ne
of
the
co
mp
an
ies
inte
rvie
we
d w
ere
aw
are
of
an
y
occ
urr
en
ce o
f a
tw
o-t
ier
ma
rke
t.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
All
in
terv
iew
ee
s su
gg
est
ed
th
at
the
pro
tect
ion
wa
s a
lre
ad
y g
ua
ran
tee
d i
n p
rev
iou
s
con
text
by
na
tio
na
l m
etr
olo
gic
al
bo
die
s.
On
e l
arg
e c
om
pa
ny
em
ph
asi
sed
th
at
as
the
MID
is
mu
ch c
lea
rer
tha
n t
he
pre
vio
us
leg
isla
tiv
e c
on
text
, th
e c
on
sum
ers
are
be
tte
r p
rote
cte
d.
Fu
rth
erm
ore
, a
s d
istr
ibu
tors
inst
all
th
e m
ete
rs t
he
y h
av
e a
n i
nce
nti
ve
to
en
sure
qu
ali
ty o
f th
e i
nst
rum
en
ts.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
On
e l
arg
e m
an
ufa
ctu
rer
sta
ted
th
at
be
cau
se o
f th
e a
dd
itio
na
l n
ati
on
al
spe
cifi
cati
on
s
for
use
th
e ‘
Old
an
d n
ew
’ sy
ste
ms
are
ru
nn
ing
in
pa
rall
el
an
d t
his
in
cre
ase
s w
ork
loa
d;
du
e t
o t
he
ne
w t
erm
ino
log
y in
th
e M
ID (
ne
w c
lass
A,
old
cla
ss 1
) th
e h
arm
on
ise
d E
U
sta
nd
ard
s a
re i
n c
on
flic
t w
ith
th
e I
EC
sta
nd
ard
s cr
ea
tin
g a
co
mp
lete
ly u
nn
ece
ssa
ry
com
pli
cati
on
.
Tw
o m
an
ufa
ctu
rers
sta
ted
th
at
th
ere
wa
s n
o n
oti
cea
ble
ch
an
ge
ov
era
ll a
s a
de
cre
ase
in b
urd
en
s fo
r i
nd
ust
ria
l co
mm
erc
ial
use
s h
as
be
en
co
mp
en
sate
d b
y a
sub
sta
nti
al
incr
ea
se o
f th
e a
dm
inis
tra
tiv
e b
urd
en
fo
r re
sid
en
tia
l m
ete
rs d
ue
to
th
e
rem
ain
ing
na
tio
na
l a
pp
rov
als
fo
r a
spe
cts
of
the
me
ters
. S
imp
lifi
cati
on
s a
re e
xpe
cte
d i
f
rea
ctiv
e m
ea
sure
me
nt
is a
lso
in
clu
de
d.
Ho
we
ve
r, o
ne
co
mp
an
y s
ug
ge
ste
d t
ha
t th
ere
wa
s a
sig
nif
ica
nt
incr
ea
se o
f th
e p
eri
od
ic
au
dit
co
sts
for
the
mo
du
le D
(q
ua
lity
sy
ste
m)
ass
ess
me
nt
tha
t d
id n
ot
exi
st i
n t
he
pre
vio
us
con
text
.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Eu
rele
ctri
c st
ate
d t
ha
t th
ere
is
no
re
al
rep
rese
nta
tio
n o
f in
du
stry
. W
hil
e t
he
y h
ad
con
sult
ing
ro
le f
ina
lly
all
de
cisi
on
co
nce
rnin
g M
ID w
as
tak
en
by
th
e r
eg
ula
tory
bo
die
s.
Imp
act
on
SM
Es
A
cco
rdin
g t
o o
ne
la
rge
ma
nu
fact
ure
r, S
ME
s h
av
e v
ery
lim
ite
d p
rese
nce
in
th
e m
ark
et.
Th
e M
ID i
s n
ot
exp
ect
ed
to
ha
ve
ha
d a
ny
pa
rtic
ula
r e
ffe
ct o
n t
he
m.
In a
dd
itio
n,
on
e S
ME
in
vo
lve
d i
n t
he
Ib
eri
an
pe
nin
sula
ma
rke
t, d
id n
ot
fee
l th
e
Dir
ect
ive
ha
d a
ny
ne
ga
tiv
e i
mp
act
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
75
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts (
incl
.
role
of
WE
LME
C)
Acc
ord
ing
to
Eu
rele
ctri
c in
th
e n
ew
te
rmin
olo
gy
of
the
MID
, th
e h
arm
on
ise
d E
U
sta
nd
ard
s a
re i
n c
on
flic
t w
ith
th
e I
EC
sta
nd
ard
s a
nd
th
is is
an
un
ne
cess
ary
com
pli
cati
on
. W
ELM
EC
’s g
uid
an
ce i
s p
art
ly u
ncl
ea
r. T
his
wa
s co
nfi
rme
d b
y o
ne
ma
nu
fact
ure
r. A
no
the
r m
an
ufa
ctu
rer
wa
s n
ot
aw
are
of
this
iss
ue
.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Ov
era
ll,
com
pa
nie
s a
re g
en
era
lly
ha
pp
y w
ith
th
e i
mp
lem
en
tati
on
by
no
tifi
ed
bo
die
s;
the
re w
as
no
ne
ga
tiv
e c
om
me
nts
On
e l
arg
e c
om
pa
ny
wa
s p
art
icu
larl
y h
ap
py
wit
h t
he
wo
rkin
g r
ela
tio
nsh
ip d
ev
elo
pe
d w
ith
th
e n
oti
fie
d b
od
ies.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
On
e t
rad
e a
sso
cia
tio
n m
en
tio
ne
d t
ha
t m
ark
et
surv
eil
lan
ce is
mis
sin
g f
rom
th
e M
ID
•
Tra
nsi
tio
n p
eri
od
(st
ate
d
be
ne
fits
/iss
ue
s)
Th
e 1
0 y
ea
rs p
eri
od
wa
s se
en
as
ap
pro
pri
ate
. N
on
e o
f th
e m
an
ufa
ctu
rers
we
ha
ve
spo
ke
n t
o i
de
nti
fie
d a
ny
pro
ble
ms.
Oth
er
MI-
00
4 –
He
at
me
ters
59
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e i
mp
lem
en
tati
on
of
the
Dir
ect
ive
Th
ere
is
an
ov
era
ll p
osi
tiv
e v
iew
of
the
im
ple
me
nta
tio
n o
f th
e D
ire
ctiv
e.
Acc
ord
ing
to
th
e t
rad
e a
sso
cia
tio
n (
AC
QU
A),
th
e e
xpe
rie
nce
is
ov
era
ll p
osi
tiv
e,
esp
eci
all
y t
he
fo
llo
win
g a
spe
cts:
•
pa
rtic
ipa
tio
n in
th
e w
gM
Is a
llo
ws
exc
ha
ng
e o
f p
oin
t o
f v
iew
s
•
WE
LME
C’s
gu
ide
lin
es
•
Sim
pli
fica
tio
n o
f th
e m
ark
et
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
Acc
ord
ing
to
th
e t
rad
e a
sso
cia
tio
n,
the
MID
ha
s g
on
e q
uit
e a
lo
ng
wa
y i
n s
ett
ing
-
up
a s
ing
le m
ark
et
for
30
co
un
trie
s. O
ne
co
mp
an
y s
tre
sse
d t
ha
t th
e m
ark
et
for
he
at
me
ters
is
tra
dit
ion
all
y r
ela
tiv
ely
lim
ite
d g
eo
gra
ph
ica
lly
bu
t th
e M
ID m
igh
t
all
ow
he
at
me
ters
to
exp
an
d i
n n
ew
ma
rke
ts,
alt
ho
ug
h n
o s
pe
cifi
c d
ata
or
59 B
ase
d o
n i
nte
rvie
w w
ith
th
e r
ep
rese
nta
tiv
e o
f tw
o t
rad
e a
sso
cia
tio
ns
(AQ
UA
, E
SM
IG)
an
d t
hre
e l
arg
e m
ult
ina
tio
na
l m
an
ufa
ctu
rers
La
nd
is +
Gy
r (C
H),
Ka
mst
rup
(DK
), A
llm
ess
(D
E).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
76
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
ev
ide
nce
wa
s a
va
ila
ble
.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Ap
art
fro
m t
he
‘u
sua
l;’
con
cern
on
sm
art
me
ters
, n
on
e o
f th
e p
eo
ple
we
ha
ve
spo
ke
n t
o s
ee
th
e M
ID a
s h
am
pe
rin
g i
nn
ov
ati
on
Op
tio
na
lity
- Is
it
use
d i
n t
he
se
cto
r (h
ow
ma
ny
MS
an
d w
hy
)
- Is
th
ere
ev
ide
nce
of
two
-tie
r
ma
rke
t
- Is
th
ere
ev
ide
nce
of
un
fair
com
pe
titi
on
Th
ere
is
an
im
po
rta
nt
nu
mb
er
(5 f
or
resi
de
nti
al
an
d 6
fo
r co
mm
erc
ial&
lig
ht
ind
ust
ry)
of
cou
ntr
ies
tha
t h
av
e o
pte
d o
ut
of
the
MID
. T
his
ca
n b
e a
ris
k,
bu
t
acc
ord
ing
to
AQ
UA
, fo
r th
e m
om
en
t th
ere
is
no
ev
ide
nce
to
pro
ve
or
dis
pro
ve
th
is
cla
im.
On
e l
arg
e m
an
ufa
ctu
rer
als
o s
tre
sse
d t
ha
t so
me
co
un
trie
s d
id n
ot
fee
l th
e p
oli
tica
l
ne
ed
to
op
t in
th
e l
eg
isla
tio
n s
ince
he
at
me
ters
are
vir
tua
lly
no
n-e
xist
en
t in
th
eir
cou
ntr
ies.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
Acc
ord
ing
to
on
e m
an
ufa
ctu
rer,
th
e h
ea
t m
ete
r m
ark
et
is s
o c
on
cen
tra
ted
in
Eu
rop
e t
ha
t it
wo
uld
no
t m
ak
e s
en
se f
or
ma
nu
fact
ure
rs t
o d
ev
elo
p t
wo
ty
pe
s o
f
me
ters
fo
r M
ID a
nd
no
n-M
ID m
ark
ets
.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
No
ne
of
the
co
mp
an
ies
we
ha
ve
sp
ok
en
re
ferr
ed
to
ad
dit
ion
al
ad
min
istr
ati
ve
bu
rde
n.
Th
ere
is
a g
en
era
l se
nse
th
at
the
be
ne
fits
of
ha
vin
g E
U-w
ide
ce
rtif
ica
tes
ou
tstr
ip t
he
ad
min
istr
ati
ve
bu
rde
ns
of
the
MID
. H
ow
ev
er,
no
on
e c
ou
ld p
rov
ide
ha
rd d
ata
on
th
is a
spe
ct.
Re
pre
sen
tati
on
in
th
e M
ea
suri
ng
inst
rum
en
ts c
om
mit
tee
All
th
e m
an
ufa
ctu
rers
we
sp
ok
e w
ere
ple
ase
d w
ith
th
eir
re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
t co
mm
itte
e t
hro
ug
h A
QU
A,
wh
ich
is
see
n a
s v
ery
act
ive
, it
ga
the
rs m
an
ufa
ctu
rers
’ v
iew
s, a
nd
ke
ep
th
em
up
-to
-da
te.
Th
ere
we
re n
o
issu
es/
com
pla
ints
of
un
de
r-re
pre
sen
tati
on
.
Imp
act
on
SM
Es
T
he
re w
ere
no
iss
ue
s o
n S
ME
s p
oin
ted
, th
e m
ain
re
aso
n b
ein
g t
he
do
min
an
t ro
le
of
larg
e c
om
pa
nie
s. T
he
SM
E s
urv
ey
in
dic
ate
d n
o p
rob
lem
s w
ith
th
e c
on
form
ity
ass
ess
me
nt
pro
ced
ure
s fo
r th
e S
ME
s a
nd
th
e m
ajo
rity
(>
80
%)
did
no
t in
dic
ate
an
y
ba
rrie
rs t
o t
rad
e.
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d g
uid
an
ce
do
cum
en
ts (
incl
. ro
le o
f
WE
LME
C)
Acc
ord
ing
to
AQ
UA
, th
e n
ew
gu
ida
nce
do
cum
en
ts b
y W
ELM
EC
he
lpe
d
ha
rmo
nis
ati
on
wit
hin
th
e f
ram
ew
ork
of
the
MID
. I
t w
as
con
sid
ere
d a
s u
sefu
l
tow
ard
s h
arm
on
isin
g v
iew
s o
n t
he
MID
an
d d
ev
elo
p a
co
mm
on
in
terp
reta
tio
n.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
AQ
UA
sta
ted
th
at
the
im
ple
me
nta
tio
n b
y n
oti
fie
d b
od
ies
wa
s ra
the
r sa
tisf
act
ory
an
d t
ha
t W
ELM
EC
gu
ide
lin
es
we
re c
on
sid
ere
d a
s h
elp
ing
no
tifi
ed
bo
die
s.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
77
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
AQ
UA
un
de
rlin
ed
th
e l
ack
of
ma
rke
t su
rve
illa
nce
in
th
e M
ID a
s th
e m
ain
sho
rtco
min
gs.
Th
e i
ntr
od
uct
ion
of
the
NLF
an
d t
he
re
qu
ire
me
nt
it i
ntr
od
uce
d i
s
con
sid
ere
d a
s a
po
siti
ve
ste
p b
y A
QU
A a
lth
ou
gh
it
is n
ot
cle
ar
if i
t w
ill
be
suff
icie
nt.
Th
e c
om
pa
nie
s d
id n
ot
see
m t
o t
hin
k t
his
wa
s a
pro
ble
m a
s th
ey
ha
ve
the
ir t
rust
ed
cu
sto
me
rs i
n d
iffe
ren
t n
ati
on
al
ma
rke
ts.
•
Tra
nsi
tio
n p
eri
od
(st
ate
d
be
ne
fits
/iss
ue
s)
No
in
terv
iew
ee
co
nsi
de
red
th
e 1
0 y
ea
r tr
an
siti
on
pe
rio
d a
s a
n i
ssu
e
Oth
er
MI-
00
5a
– F
ue
l D
isp
en
sers
60
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
(ov
era
ll)
Th
e e
xpe
rie
nce
is
tha
t d
esp
ite
ge
ne
ral
imp
rov
em
en
ts in
co
mp
ari
son
to
th
e p
ast
an
d
the
cle
ar
be
ne
fits
of
the
use
of
a s
ing
le c
ert
ific
ati
on
th
ere
are
a n
um
be
r o
f is
sue
s
tha
t a
pp
ea
r to
ca
use
pro
ble
ms
to m
an
ufa
ctu
rers
an
d t
o C
As.
Th
e m
ain
iss
ue
s (d
iscu
sse
d b
elo
w)
are
:
•
Th
e p
rob
lem
ati
c si
tua
tio
n t
ha
t cr
ea
tes
ob
sta
cle
s to
th
e m
ark
et
con
cern
ing
se
lf
serv
ing
de
vic
es
an
d t
he
op
po
rtu
nit
y t
o m
ix a
nd
co
nn
ect
old
se
lf-s
erv
ing
de
vic
es
wit
h M
ID c
ert
ifie
d f
ue
l d
isp
en
sers
in
pe
tro
l st
ati
on
s (a
nd
th
e r
ev
ers
e)
an
d t
he
dif
fere
nce
s in
th
e s
itu
ati
on
am
on
g M
em
be
r S
tate
s
•
Th
e d
iffe
ren
t a
pp
roa
che
s fo
llo
we
d b
y a
uth
ori
tie
s in
so
me
MS
s in
re
ga
rds
to
ad
dit
ion
al
req
uir
em
en
ts a
nd
ch
eck
s e
ve
n i
f th
ey
fa
ll o
uts
ide
MID
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
CE
CO
D a
nd
a n
um
be
r o
f m
an
ufa
ctu
rers
sta
ted
th
at
the
re a
re i
mp
rov
em
en
ts i
n
com
pa
riso
n t
o t
he
pa
st b
ase
d o
n t
he
use
of
sin
gle
ce
rtif
ica
te b
ut
an
eff
icie
nt
sin
gle
ma
rke
t is
sti
ll n
ot
op
era
tin
g d
ue
to
th
e a
dd
itio
na
l re
qu
ire
me
nt
in s
om
e c
ou
ntr
ies
for
ad
dit
ion
al
che
cks
on
iss
ue
s li
ke C
E+
M m
ark
se
als
. H
ow
ev
er,
oth
er
ma
nu
fact
ure
rs
CE
CO
D r
ep
ort
s th
at
in s
om
e
Me
mb
er
sta
tes
(re
fere
nce
ma
de
to S
pa
in,
Ita
ly)
the
re a
re
ad
dit
ion
al
req
uir
em
en
ts (
e.g
. si
ze
60 B
ase
d o
n i
nte
rvie
ws
wit
h t
he
re
pre
sen
tati
ve
of
the
tra
de
ass
oci
ati
on
, o
ne
in
de
pe
nd
en
t e
xpe
rt (
Te
rry
Ro
ge
rs),
PE
IMF
(U
K+
IE)
an
d 3
la
rge
or
ve
ry l
arg
e
ma
nu
fact
ure
rs (
PE
TR
OT
EC
-PT
, G
ILB
AR
CO
- U
K,
SC
HE
IDT
an
d B
AC
HM
AN
-DE
).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
78
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
(Pe
tro
tec,
S&
B)
we
re m
ore
po
siti
ve
sta
tin
g t
ha
t th
e a
cce
ss t
o a
big
ge
r m
ark
et
is
ind
ee
d t
he
ca
se a
nd
did
no
t re
po
rt s
imil
ar
pro
ble
ms.
Th
e p
rob
lem
ap
pe
ars
to
be
lim
ite
d t
o o
nly
so
me
co
un
trie
s.
An
oth
er
imp
ort
an
t p
rob
lem
wh
ich
, a
cco
rdin
g t
o t
he
in
du
stry
(in
clu
din
g C
EC
OD
an
d
firm
s),
aff
ect
s th
e o
pe
rati
on
of
the
ma
rke
t a
nd
th
e a
do
pti
on
of
MID
in
stru
me
nts
con
cern
s th
e i
na
bil
ity
to
mix
old
er
na
tio
na
l ce
rtif
ied
eq
uip
me
nt
wit
h M
ID c
ert
ifie
d
on
es.
It
con
cern
s sy
ste
ms
for
un
ma
nn
ed
sta
tio
ns
(se
lf-s
erv
ice
an
d p
ay
me
nt
in o
ne
syst
em
) o
r st
ati
on
s w
ith
se
lf-s
erv
ice
de
vic
es
wit
h p
ay
ing
at
the
kio
sk a
nd
sta
ckin
g o
f
the
co
nsu
me
rs t
ran
sact
ion
(m
ix a
nd
ma
tch
pro
ble
m).
Acc
ord
ing
to
CE
CO
D,
the
y
rep
rese
nt
30
% o
f th
e m
ark
et
wit
h i
ncr
ea
sin
g t
ren
ds.
Fo
llo
win
g t
he
MID
, e
xist
ing
syst
em
s th
at
are
ap
pro
ve
d a
cco
rdin
g t
o n
ati
on
al
leg
isla
tio
n c
an
be
pla
ced
on
th
e
ma
rke
t a
nd
pu
t in
to u
se d
uri
ng
th
e t
ran
siti
on
pe
rio
d,
bu
t th
ey
are
no
t a
llo
we
d t
o b
e
alt
ere
d.
Th
is m
ea
ns
tha
t a
sy
ste
m a
pp
rov
ed
un
de
r o
ld n
ati
on
al
leg
isla
tio
n c
an
no
t b
e
up
gra
de
d w
ith
an
“M
ID”
com
po
ne
nt
(PO
S o
r d
isp
en
ser
wit
ho
ut
see
kin
g M
ID
ap
pro
va
l fo
r th
e c
om
ple
te s
yst
em
. A
s so
me
co
mp
an
ies
are
pro
du
cers
of
on
ly t
he
PO
S t
his
ma
y i
ncl
ud
e t
he
m g
ett
ing
ap
pro
va
l fr
om
th
e m
an
ufa
ctu
rers
of
the
dif
fere
nt
dis
pe
nse
rs t
o i
ncl
ud
e t
he
ir P
OS
in
th
e M
ID c
ert
ific
ate
of
the
dis
pe
nse
r. C
urr
en
tly
,
du
rin
g t
he
tra
nsi
tio
n p
eri
od
, th
ere
are
dif
fere
nt
reg
ime
s a
mo
ng
co
un
trie
s in
re
lati
on
to t
he
acc
ep
tan
ce o
f co
mb
inin
g n
ew
(M
ID c
ert
ifie
d)
an
d o
ld (
na
tio
na
lly
ce
rtif
ied
)
dis
pe
nse
rs a
nd
po
int
of
sale
s (P
OS
) in
pe
tro
l st
ati
on
s. (
UK
an
d N
L n
ot
all
ow
ing
mix
ing
of
old
an
d n
ew
un
til
rece
ntl
y a
nd
cu
rre
ntl
y a
llo
win
g o
nly
if t
he
y a
re a
lso
con
ne
cte
d t
o o
the
r p
re-M
ID s
yst
em
s).
It i
s su
gg
est
ed
as
rep
rese
nti
ng
ba
rrie
rs t
o
tra
de
bu
t a
lso
a d
isin
cen
tiv
e t
o r
en
ew
eq
uip
me
nt
(un
less
th
e d
eci
sio
n i
s m
ad
e t
o
ren
ew
bo
th e
qu
ipm
en
ts a
t th
e s
am
e t
ime
).
In
du
stry
an
d u
ser
rep
rese
nta
tiv
es
sug
ge
st t
ha
t th
is c
lea
rly
lim
its
the
op
era
tio
n o
f
the
ma
rke
t in
th
ose
co
un
trie
s th
at
ha
ve
im
po
se t
his
re
qu
ire
me
nt
– i
n t
he
UK
on
ly
10
% h
as
swit
che
d t
o M
ID d
isp
en
sers
- a
nd
it
is e
xpe
cte
d t
o d
o t
ha
t e
ve
n a
fte
r th
e
of
CE
ma
rk o
r a
dd
itio
na
l se
als
in
Ita
ly a
nd
sim
ila
r ty
pe
s o
f ch
eck
s
in S
pa
in)
wh
ich
are
no
t le
ga
l
acc
ord
ing
to
th
e D
ire
ctiv
e b
ut
ad
d c
ost
s a
nd
are
tim
e-
con
sum
ing
wh
en
th
ey
en
d u
p
cha
lle
ng
ed
in
co
urt
s61
61 T
he
Sp
an
ish
CA
str
on
gly
ch
all
en
ge
d t
ha
t a
nd
su
gg
est
ed
th
at
wh
ile
CE
CO
D h
as
be
en
in
vit
ed
in
a n
um
be
r o
f o
cca
sio
ns
to r
ep
ort
an
d p
rov
ide
ev
ide
nce
th
is h
as
no
t ta
ke
n p
lace
.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
79
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
tra
nsi
tio
n p
eri
od
sin
ce t
he
lif
eti
me
of
dis
pe
nse
rs i
s u
p t
o 2
0 y
ea
rs.
It i
s a
lso
se
en
as
forc
ing
use
rs t
o e
ith
er
cha
ng
e b
oth
in
stru
me
nts
or
on
ly m
ak
e r
ep
air
s w
ith
ou
t
ma
kin
g f
ull
use
of
the
eq
uip
me
nt.
Th
e p
rop
osa
l o
f C
EC
OD
is
to a
do
pt
a s
ub
-ass
em
bly
fo
r p
oin
ts o
f sa
le.
On
th
is i
ssu
e,
a
big
nu
mb
er
of
CA
s a
lso
ag
ree
s th
at
the
sit
ua
tio
n i
s p
rob
lem
ati
c w
hil
e t
he
CA
s in
th
e
cou
ntr
ies
tha
t h
av
e a
do
pte
d a
mo
re s
tric
t a
pp
roa
ch d
uri
ng
th
e t
ran
siti
on
pe
rio
d (
UK
an
d N
L) c
on
sid
ers
th
at
it i
s a
pp
rop
ria
te f
or
con
sum
er
pro
tect
ion
. T
he
iss
ue
ha
s b
ee
n
rais
ed
an
d w
ell
do
cum
en
ted
in
th
e c
on
text
of
WE
LME
C a
nd
a l
arg
e n
um
be
r o
f C
As
sup
po
rt a
su
b-a
sse
mb
ly a
pp
roa
ch b
ut
this
is
no
t u
na
nim
ou
s.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Th
ere
we
re b
oth
po
siti
ve
an
d n
eg
ati
ve
vie
ws
in r
ela
tio
n t
o t
he
ro
le o
f th
e M
ID i
n
tech
no
log
ica
l in
no
va
tio
n:
On
e m
an
ufa
ctu
rer
sug
ge
ste
d t
ha
t th
e g
rea
ter
ma
rke
ts a
nd
th
e c
rea
tio
n o
f si
ng
le s
et
of
req
uir
em
en
ts i
s p
osi
tiv
e a
s it
pro
vid
es
ince
nti
ve
fo
r d
ev
elo
p m
ark
ets
fo
r la
rge
r
ma
rke
ts (
no
exa
mp
le m
en
tio
ne
d t
ho
ug
h).
On
th
e o
the
r h
an
d,
CE
CO
D s
ug
ge
ste
d t
ha
t th
e D
ire
ctiv
e i
s ra
the
r p
resc
rip
tiv
e a
nd
the
ess
en
tia
l re
qu
ire
me
nts
are
ra
the
r li
mit
ing
cre
ati
ng
lim
ita
tio
ns
to m
an
ufa
ctu
rers
in t
erm
s o
f in
no
va
tio
n (
alt
ho
ug
h n
o s
pe
cifi
c e
xam
ple
s w
ere
giv
en
).
It i
s a
gre
ed
by
alm
ost
all
in t
he
in
du
stry
(C
EC
OD
, fi
rms
an
d u
sers
) th
at
the
ab
sen
ce
of
som
e p
rov
isio
n f
or
test
ing
sy
ste
ms
(in
clu
din
g f
ue
l d
isp
en
sers
an
d s
elf
-se
rvic
e
ma
chin
es/
PO
S)
on
pe
tro
l st
ati
on
sit
es
po
ses
dif
ficu
ltie
s to
in
no
va
tio
n.
Ma
nu
fact
ure
rs a
re n
ot
all
ow
ed
to
co
nd
uct
pro
pe
r m
ark
et
test
s fo
r n
ew
pro
du
cts
an
d s
erv
ice
s th
at
wo
uld
re
qu
ire
in
sta
lle
d u
nit
s w
ith
ou
t fi
rst
go
ing
th
rou
gh
th
e M
ID
cert
ific
ati
on
pro
ced
ure
s. A
cco
rdin
g t
o o
ne
co
mp
an
y t
he
y c
an
on
ly d
o s
om
e t
est
s in
the
ir h
om
e c
ou
ntr
y.
Eit
he
r w
ay
th
is i
s se
en
as
a r
ep
rese
nti
ng
a l
imit
ati
on
to
th
e
de
ve
lop
me
nt
of
ne
w p
rod
uct
s.
A c
om
pa
ny
sta
ted
th
at
the
y c
an
on
ly d
o t
est
s in
th
eir
ho
me
cou
ntr
y u
sin
g M
ID c
ert
ifie
d
inst
rum
en
ts b
ut
cou
ld n
ot
po
ssib
ly t
est
in
oth
er
cou
ntr
ies.
Op
tio
na
lity
- Is
it
use
d i
n t
he
se
cto
r
- Is
th
ere
ev
ide
nce
of
two
-
tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
com
pe
titi
on
Op
tio
na
lity
is n
ot
use
d i
n t
he
ca
se o
f M
I-0
05
a.
(on
ly o
ne
co
un
try
- M
T)
CE
CO
D c
on
sid
ers
op
tio
na
lity
as
un
fair
bu
t th
ere
wa
s n
o e
vid
en
ce p
rov
ide
d (
by
CE
CO
D o
r a
ny
co
mp
an
y)
of
a t
wo
tie
r m
ark
et
or
un
fair
co
mp
eti
tio
n d
ue
to
it.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
80
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
In t
he
UK
, u
sers
of
fue
l d
isp
en
ser
syst
em
s (P
EIM
L) s
ug
ge
ste
d t
ha
t th
e i
ntr
od
uct
ion
of
the
MID
bro
ug
ht
gre
ate
r le
ve
l o
f p
rote
ctio
n t
hro
ug
h t
he
in
tro
du
ctio
n o
f th
e
ess
en
tia
l re
qu
ire
me
nts
an
d t
he
ir a
pp
lica
tio
n a
cro
ss t
he
EU
.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Th
ere
is
at
this
po
int
no
cle
ar
vie
w o
f th
e c
ha
ng
e i
n a
dm
inis
tra
tiv
e c
ost
wit
h
con
flic
tin
g i
nfo
rma
tio
n f
rom
th
e d
iffe
ren
t in
terv
iew
s. I
t se
em
s th
at
wh
ile
ch
arg
es
of
no
tifi
ed
bo
die
s in
ge
ne
ral
incr
ea
sed
-d
ue
to
mo
re t
ho
rou
gh
te
sts
an
d l
on
ge
r ti
me
to
issu
e a
ce
rtif
ica
te -
th
e o
ve
rall
co
sts
ha
ve d
ecr
ea
sed
– p
art
icu
larl
y f
or
tho
se w
ith
pre
sen
ce i
n m
ult
iple
ma
rke
ts.
CE
CO
D s
ug
ge
ste
d t
ha
t a
dm
inis
tra
tiv
e b
urd
en
s h
av
e n
ot
be
en
re
du
ced
as
mu
ch a
s it
wa
s e
xpe
cte
d d
ue
to
th
e u
se o
f si
ng
le E
U-w
ide
ce
rtif
ica
te a
s in
ma
ny
MS
s th
ere
are
ad
dit
ion
al
req
uir
em
en
ts p
ose
d w
hic
h,
acc
ord
ing
to
CE
CO
D,
are
ill
eg
al.
On
e m
an
ufa
ctu
rer
sta
ted
als
o a
co
st r
ed
uct
ion
fo
r u
sers
(p
etr
ol
sta
tio
ns)
as
the
re i
s
no
ne
ed
fo
r in
itia
l v
eri
fica
tio
n
On
e c
om
pa
ny
sta
ted
th
at
No
tifi
ed
Bo
die
s te
nd
to
ch
arg
e
mo
re t
ha
n i
n t
he
pa
st f
or
the
cert
ific
ati
on
(u
p t
o 5
0%
fro
m t
he
pre
vio
us
pro
ced
ure
s) a
nd
ta
ke
mo
re t
ime
be
cau
se t
he
pro
ced
ure
s a
re m
ore
th
oro
ug
h.
An
oth
er
com
pa
ny
sta
ted
th
at
the
ov
era
ll a
dm
inis
tra
tiv
e c
ost
s h
av
e
ma
rgin
all
y d
ecr
ea
sed
an
d t
ha
t
the
re
qu
ire
d t
ime
is
no
t v
ery
dif
fere
nt
(no
est
ima
te p
rov
ide
d).
Ho
we
ve
r, t
wo
mo
re f
irm
s w
ith
pre
sen
ce i
n o
ve
r 1
0 E
U c
ou
ntr
ies
sta
ted
th
at
the
y h
ad
exp
eri
en
ced
a r
ed
uct
ion
of
aro
un
d 8
0%
in
cost
s a
nd
th
at
the
ce
rtif
ica
tio
n
pro
cess
ha
s b
eco
me
fa
ste
r (3
-4
mo
nth
s in
co
mp
ari
son
to
up
to
a
ye
ar)
Re
pre
sen
tati
on
in
th
e M
ea
suri
ng
inst
rum
en
ts c
om
mit
tee
Th
e p
art
icip
ati
on
in
th
e w
gM
Is a
nd
th
e o
pp
ort
un
ity
to
exp
ress
vie
ws
is w
elc
om
ed
by
CE
CO
D.
Th
e m
ain
iss
ue
ra
ise
d i
s th
e r
ep
rese
nta
tio
n a
nd
in
flu
en
ce i
n W
ELM
EC
,
wh
ich
, in
th
e a
bse
nce
of
Eu
rop
ea
n s
tan
da
rds,
is
see
n a
s h
av
ing
in
cre
ase
d r
ole
thro
ug
h t
he
iss
uin
g o
f g
uid
an
ce d
ocu
me
nts
. In
th
is a
rea
, C
EC
OD
co
nsi
de
rs t
ha
t th
eir
role
as
ob
serv
ers
- i
s n
ot
ad
eq
ua
te.
Imp
act
on
SM
Es
C
EC
OD
su
gg
est
ed
th
at
un
de
r th
e c
urr
en
t li
mit
ati
on
s fo
r co
mb
inin
g o
ld a
nd
ne
w
eq
uip
me
nt,
sm
all
ma
nu
fact
ure
rs t
ha
t u
sua
lly
pro
du
ce a
nd
se
ll in
div
idu
al
pa
rts
of
the
to
tal
un
it (
PO
S o
r d
isp
en
ser)
ca
nn
ot
ha
ve
th
eir
pro
du
cts
CE
ce
rtif
ied
an
d a
re i
n a
dis
ad
va
nta
ge
d p
osi
tio
n a
ga
inst
la
rge
ma
nu
fact
ure
rs.
Co
nsu
me
rs b
uy
ing
in
teg
rate
d
.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
81
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
syst
em
s a
re e
xpe
cte
d t
o f
av
ou
r la
rge
ma
nu
fact
ure
rs t
ha
t h
av
e t
he
wh
ole
sy
ste
m
cert
ifie
d.
Ho
we
ve
r, n
o r
ea
l li
fe e
xam
ple
s w
ere
pro
vid
ed
.
Th
e S
ME
su
rve
y (
ba
sed
on
re
spo
nse
s o
f 2
4 f
irm
s) d
id n
ot
ind
ica
te t
ha
t S
ME
s fa
ce
an
y b
arr
iers
to
tra
de
an
d t
he
co
nfo
rmit
y a
sse
ssm
en
t p
roce
du
res
did
no
t a
lso
ap
pe
ar
to p
ose
pro
ble
ms
(all
re
spo
nd
en
ts c
on
sid
er
the
m a
de
qu
ate
).
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d g
uid
an
ce
do
cum
en
ts (
incl
. ro
le o
f
WE
LME
C)
Th
ere
are
no
Eu
rop
ea
n s
tan
da
rds
issu
ed
as
far
as
no
fo
rma
l re
qu
est
ha
s b
ee
n
pla
ced
. O
IML
no
rma
tiv
e d
ocu
me
nts
are
no
t co
nsi
de
red
sa
tisf
act
ory
by
CE
CO
D a
nd
som
e c
om
pa
nie
s. T
he
y a
re c
on
sid
ere
d r
ath
er
stri
ct a
nd
pre
scri
pti
ve
an
d t
he
ind
ust
ry h
as
no
ro
le i
n t
he
ir d
raft
ing
.
Sim
ila
rly
WE
LME
C d
ocu
me
nt
are
se
en
as
be
ing
to
o p
resc
rip
tiv
e a
nd
, a
cco
rdin
g t
o
CE
CO
D a
nd
alm
ost
all
ma
nu
fact
ure
rs,
the
no
tifi
ed
bo
die
s te
nd
to
use
th
em
as
if t
he
y
are
sta
nd
ard
s a
nd
are
re
luct
an
t to
acc
ep
t o
the
r a
pp
roa
che
s.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
As
ab
ov
e,
CE
CO
D a
nd
co
mp
an
ies
rep
ort
ed
th
at
no
tifi
ed
bo
die
s te
nd
to
use
WE
LME
C
gu
ide
lin
es
rath
er
stri
ctly
an
d b
e l
ess
op
en
to
oth
er
ap
pro
ach
es
po
sin
g li
mit
ati
on
s o
r
de
lay
s in
ce
rtif
ica
tio
n p
roce
du
re.
Fu
rth
erm
ore
, C
EC
OD
re
po
rts
tha
t N
B
rep
ort
s/ce
rtif
ica
tes
are
va
ryin
g i
n c
on
ten
t.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
Ind
ust
ry (
CE
CO
D a
nd
so
me
ma
nu
fact
ure
rs)
rep
ort
ed
th
at
ma
rke
t su
rve
illa
nce
is
in
ma
ny
co
un
trie
s li
mit
ed
or
ab
sen
t. O
ne
ma
nu
fact
ure
r su
gg
est
ed
th
at
in G
ree
ce t
he
re
is c
om
ple
te a
bse
nce
of
an
y s
urv
eil
lan
ce w
ith
no
te
stin
g o
f C
E+
M m
ark
ing
an
d f
ree
circ
ula
tio
n o
f a
ll t
yp
es
of
dis
pe
nse
rs.
AS
su
gg
est
ed
ab
ov
e,
the
re a
re a
lso
pro
ble
ms
du
e t
o t
he
ad
dit
ion
al
req
uir
em
en
ts p
ose
d b
y s
om
e a
uth
ori
tie
s (I
T,
ES
) th
at
go
be
yo
nd
MID
re
qu
ire
me
nts
.
•
Tra
nsi
tio
n p
eri
od
T
he
tra
nsi
tio
n p
eri
od
is c
on
sid
ere
d r
ath
er
lon
g b
y C
EC
OD
an
d s
om
e m
an
ufa
ctu
rers
.
CE
CO
D c
on
sid
ere
d t
ha
t m
ore
cle
ar
gu
ide
lin
es
fro
m t
he
Co
mm
issi
on
wo
uld
he
lp
solv
e t
his
pro
ble
m.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
82
MI-
00
5b
– O
the
r li
qu
id d
isp
en
sin
g s
yst
em
s 6
2
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
As
in t
he
ca
se o
f fu
el
dis
pe
nse
rs t
he
vie
w w
ere
ra
the
r m
ixe
d.
CE
CO
D r
eco
gn
ise
d t
he
be
ne
fit
fro
m a
cce
ssin
g a
wid
er
ma
rke
t o
ne
co
mp
an
y a
dd
ed
th
e c
lea
r b
en
efi
t fr
om
th
e o
pp
ort
un
ity
for
in-h
ou
se v
eri
fica
tio
n.
Th
e m
ain
pro
ble
ms/
issu
es
con
cern
ed
th
e n
ee
d f
or
ma
ny
ce
rtif
ica
tio
ns
for
ev
ery
co
mb
ina
tio
n
of
dif
fere
nt
com
po
ne
nts
bu
t a
lso
th
e u
ncl
ea
r si
tua
tio
n i
n r
ela
tio
n t
o t
he
co
mb
ina
tio
n o
f n
ew
an
d o
ld e
qu
ipm
en
t.
In r
esp
ect
to
th
e s
eco
nd
at
lea
st t
wo
co
mp
an
ies
sta
ted
th
at
un
de
r th
e M
ID m
an
ufa
ctu
rers
cou
ld o
nly
se
ll c
om
ple
te s
yst
em
s. S
ep
ara
te e
qu
ipm
en
t ca
nn
ot
be
so
ld w
ith
an
MID
ce
rtif
ica
te
as
on
ly c
om
ple
te s
yst
em
s ca
n b
e c
ert
ifie
d a
nd
th
is i
s se
en
as
lim
itin
g t
he
acc
ess
of
som
e
com
pa
nie
s to
th
e m
ark
et.
Ho
we
ve
r, W
ELM
EC
su
gg
est
ed
th
at
this
is
no
t a
big
ch
an
ge
fro
m t
he
pre
vio
us
sch
em
e a
s a
lre
ad
y m
ost
co
un
trie
s h
ad
mo
ve
d t
ow
ard
s th
e f
ull
sys
tem
ap
pro
ach
.
As
sug
ge
ste
d b
y o
ne
ma
nu
fact
ure
r cu
sto
me
rs t
en
d
to a
sk f
or
sep
ara
te
pa
rts/
com
po
ne
nts
to
be
MID
-
cert
ifie
d b
it t
his
ca
nn
ot
tak
e
pla
ce.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
Th
e i
nte
rvie
we
es
reco
gn
ise
d a
cle
ar
(or
po
ten
tia
l b
en
efi
t) f
rom
th
e u
se o
f a
sin
gle
ce
rtif
ica
te.
Ho
we
ve
r, i
nte
rvie
ws
wit
h W
ELM
EC
re
ferr
ed
to
th
e p
ract
ice
of
som
e M
S t
o a
sk f
or
na
tio
na
l
cert
ific
ati
on
/ve
rifi
cati
on
fo
r th
e u
se o
f in
stru
me
nts
ju
st 2
mo
nth
s a
fte
r th
eir
pla
cin
g i
n
ma
rke
t. T
he
se a
re b
ase
d o
n d
iffe
ren
t n
ati
on
al
reg
ula
tio
ns
(no
t h
arm
on
ise
d)
an
d e
ffe
ctiv
ely
cre
ate
ma
rke
t b
arr
iers
th
at
eff
ect
ive
ly d
o n
ot
all
ow
ma
kin
g f
ull
use
of
the
MID
be
ne
fits
. A
t
lea
st o
ne
co
mp
an
y a
gre
ed
an
d s
tate
d t
ha
t th
is i
s a
dis
ince
nti
ve
fo
r e
nte
rin
g o
the
r m
ark
ets
.
As
in t
he
ca
se o
f fu
el
dis
pe
nse
rs,
CE
CO
D r
efe
rs t
o b
arr
ier
to f
ree
cir
cula
tio
n in
re
lati
on
to
th
e
pro
cess
of
ren
ew
ing
exi
stin
g in
stru
me
nts
in
fix
ed
in
sta
lla
tio
ns
(tru
ck l
oa
din
g m
ea
suri
ng
syst
em
or
a m
ea
suri
ng
sy
ste
m o
n p
ipe
lin
e o
r fo
r lo
ad
ing
sh
ips,
etc
.).
Un
de
r th
e M
ID,
the
up
gra
de
of
an
exi
stin
g o
ld s
yste
m w
ith
a c
ha
ng
e o
f a
co
mp
on
en
t –
an
d n
ot
a n
ew
on
e –
ca
n
on
ly b
e d
on
e b
y r
ep
laci
ng
an
eq
uip
me
nt
wit
h t
ha
t o
f th
e s
am
e m
an
ufa
ctu
rer
or
bu
yin
g a
ne
w
MID
sy
ste
m.
Th
is,
acc
ord
ing
to
CE
CO
D,
me
an
s a
dd
itio
na
l o
ve
rall
co
sts
for
the
ma
rke
t o
f u
p t
o
€2
3m
illi
on
an
d im
po
rta
nt
lim
ita
tio
ns
for
com
pa
nie
s th
at
on
ly m
an
ufa
ctu
re c
om
po
ne
nts
fo
r
MIs
. C
EC
OD
su
gg
est
s a
ga
in t
ha
t a
n i
ntr
od
uct
ion
of
sub
-ass
em
bli
es
un
de
r M
I-0
05
an
d
de
fin
itio
n o
f th
e c
om
pa
tib
ilit
y re
qu
ire
me
nts
sh
ou
ld s
olv
e t
he
pro
ble
m.
Ag
ain
, th
is i
s w
ell
62 C
EC
OD
, Is
oil
Im
pia
nti
(IT
) ,
Fla
co (
DE
), A
cra
m (
IT)
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
83
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
do
cum
en
ted
th
rou
gh
WE
LME
C p
roce
du
res
bu
t th
ere
is
no
un
an
imit
y a
s a
nu
mb
er
of
cou
ntr
ies
stil
l co
nsi
de
r th
at
a s
ub
-ass
em
bly
is
no
t a
pp
rop
ria
te.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Ov
era
ll,
the
co
mp
an
ies
do
no
t se
e a
ny
im
pa
ct o
f th
e D
ire
ctiv
e a
s th
e m
ain
dri
ver
for
mo
st o
f
the
m i
s th
e c
om
pe
titi
on
.
In t
he
ca
se o
f so
ftw
are
re
late
d t
o t
he
eq
uip
me
nt
the
y p
rod
uce
, th
ey
su
gg
est
ed
th
at
the
MID
req
uir
em
en
ts a
re t
oo
re
stri
ctiv
e f
or
inn
ov
ati
on
(e
.g.
the
ne
ed
to
se
pa
rate
cle
arl
y m
etr
olo
gic
al
an
d n
on
-me
tro
log
ica
l p
art
th
at
did
no
t e
xist
in
th
e p
ast
).
Op
tio
na
lity
- Is
it
use
d i
n t
he
sect
or
- Is
th
ere
ev
ide
nce
of
two
-tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
co
mp
eti
tio
n
Op
tio
na
lity
ha
s b
ee
n u
sed
in
th
is c
ate
go
ry b
y a
nu
mb
er
of
cou
ntr
ies
(4-5
) m
ain
ly c
on
cern
ing
cry
og
en
ic a
nd
liq
ue
fie
d g
as
an
d m
ilk
dis
pe
nse
rs.
Th
e b
asi
s is
oth
er
the
ab
sen
ce f
rom
th
e
ma
rke
t o
r th
at
it w
as
see
n a
s n
ece
ssa
ry t
o h
av
e m
an
da
tory
re
gu
lati
on
to
pro
tect
cu
sto
me
rs.
No
su
ch e
vid
en
ce p
rov
ide
d b
y c
om
pa
nie
s o
f tw
o t
ier
ma
rke
ts i
n t
he
se
cto
rs c
ov
ere
d a
nd
of
un
fair
co
mp
eti
tio
n.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
No
iss
ue
s ra
ise
d b
y a
ny
in
terv
iew
ee
on
iss
ue
s o
f co
nsu
me
r p
rote
ctio
n.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Th
ere
is
no
cle
ar
vie
w c
on
cern
ing
th
e c
ha
ng
es
in t
he
ad
min
istr
ati
ve
co
sts
be
cau
se o
f th
e M
ID.
Th
e f
ocu
s is
on
th
e c
ert
ific
ati
on
co
sts
wh
ere
fe
es
of
NB
s re
po
rte
d v
ary
by
up
to
30
%.
On
e c
om
pa
ny
sta
ted
th
at
ind
ivid
ua
l ce
rtif
ica
tes
ha
ve
be
com
e m
uch
mo
re e
xpe
nsi
ve
wh
ile
an
oth
er
com
pa
ny
in
DE
did
no
t se
e a
ny
ch
an
ge
in
th
e p
rice
or
tim
e.
Acc
ord
ing
to
on
e m
an
ufa
ctu
rer,
ad
dit
ion
al
cost
s a
re i
ncu
rre
d w
he
n t
he
re i
s a
re
qu
est
fo
r a
cha
ng
e i
n o
nly
on
e c
om
po
ne
nt
of
the
sy
ste
m a
s th
ere
is
stil
l a r
eq
uir
em
en
t fo
r n
ew
cert
ific
ati
on
. T
his
me
an
s m
an
y m
ore
ce
rtif
ica
tes
tha
t in
th
e p
ast
an
d i
ncr
ea
sed
co
sts
for
ea
ch
ne
w p
rod
uct
.
Ma
nu
fact
ure
rs s
tate
d t
ha
t in
the
pa
st t
he
y w
ou
ld n
ot
spe
nd
mo
re t
ha
n €
5,0
00
fo
r a
syst
em
, cu
rre
ntl
y in
so
me
no
tifi
ed
bo
die
s in
so
me
cou
ntr
ies
ov
er
€2
5,0
00
. F
or
mo
dif
ica
tio
ns,
th
e t
ime
sp
en
t
cou
ld r
ea
ch 6
0 d
ay
s w
ith
2
pe
op
le o
ccu
pie
d f
ull
tim
e t
ha
t
wa
s a
sig
nif
ica
nt
ad
min
istr
ati
ve
bu
rde
n.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
Th
e p
art
icip
ati
on
an
d t
he
op
po
rtu
nit
y t
o e
xpre
ss v
iew
s a
re w
elc
om
ed
. T
he
ma
in i
ssu
e r
ais
ed
is t
he
re
pre
sen
tati
on
an
d i
nfl
ue
nce
in
WE
LME
C,
wh
ich
, in
th
e a
bse
nce
of
Eu
rop
ea
n
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
84
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
com
mit
tee
st
an
da
rds,
is
see
n a
s h
av
ing
in
cre
ase
d r
ole
th
rou
gh
th
e i
ssu
ing
of
gu
ida
nce
do
cum
en
ts.
In t
his
are
a,
CE
CO
D c
on
sid
ers
th
at
the
ir r
ole
as
ob
serv
ers
- i
s n
ot
con
sid
ere
d a
de
qu
ate
.
Imp
act
on
SM
Es
C
EC
OD
an
d s
om
e f
irm
s su
gg
est
th
at
SM
Es
tha
t p
rod
uce
co
mp
on
en
ts c
an
no
t g
et
MID
cert
ific
ati
on
an
d t
his
pu
ts t
he
m i
n d
isa
dv
an
tag
e.
An
oth
er
pro
ble
m p
art
icu
larl
y f
or
sma
ll c
om
pa
nie
s w
ith
lim
ite
d d
istr
ibu
tio
n n
etw
ork
s
con
cern
ed
in
stru
me
nts
th
at
ne
ed
to
be
ce
rtif
ied
on
sit
e w
hic
h a
re b
ou
gh
t th
rou
gh
dis
trib
uto
rs.
Ma
nu
fact
ure
rs a
re r
esp
on
sib
le b
ut
usu
all
y d
o n
ot
kn
ow
wh
ere
th
ey
are
in
sta
lle
d.
Th
ere
is
a p
rob
lem
of
ma
na
gin
g t
ime
an
d r
eso
urc
es
if t
he
y d
o n
ot
ha
ve
lo
cal
rep
rese
nta
tiv
es
an
d t
he
co
sts
we
re t
ran
sfe
rre
d t
o t
he
co
nsu
me
r.
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts
(in
cl.
role
of
WE
LME
C)
Th
e c
om
pa
nie
s su
gg
est
ed
th
at
OIM
L st
an
da
rds
are
wid
ely
re
cog
nis
ed
an
d t
he
y c
on
sid
ere
d
tha
t a
s b
en
efi
cia
l fo
r in
tern
ati
on
al
tra
de
. T
he
y d
id n
ot
see
a n
ee
d f
or
CE
N/C
EN
ELE
C
sta
nd
ard
s. W
ELM
EC
co
ntr
ibu
tio
n w
as
als
o p
osi
tiv
ely
ass
ess
ed
alt
ho
ug
h t
he
co
nti
nu
ou
s
issu
ing
of
gu
ida
nce
do
cum
en
ts o
ve
rwh
elm
s th
em
– d
iffi
cult
to
fo
llo
w
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Th
ere
we
re n
o p
art
icu
lar
pro
ble
ms
rais
ed
by
th
e i
nte
rvie
we
es
in t
erm
s o
f th
e o
pe
rati
on
of
the
NB
s. M
ost
ag
ree
d t
ha
t th
e p
rice
s ch
arg
ed
by
NB
s v
ary
gre
atl
y b
ut
this
wa
s n
ot
see
n
ne
cess
ari
ly a
s a
ne
ga
tiv
e i
ssu
e.
On
sp
eci
fic
issu
es,
on
e c
om
pa
ny
re
po
rte
d t
ha
t n
oti
fie
d
bo
die
s h
av
e d
iffe
ren
t in
terp
reta
tio
ns
as
to w
hic
h t
est
s ca
n b
e d
on
e i
n m
an
ufa
ctu
rers
’
lab
ora
tori
es.
–
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
Ov
era
ll,
the
va
ria
tio
n in
th
e l
ev
el
of
ma
rke
t su
rve
illa
nce
am
on
g M
Ss
is s
ee
n a
s th
e m
ain
pro
ble
m c
on
cern
ing
th
e i
mp
lem
en
tati
on
of
the
Dir
ect
ive
an
d o
ne
co
mp
an
y r
efe
rre
d t
o a
nu
mb
er
of
cou
ntr
ies
(IT
, E
S,
GR
, n
ew
Me
mb
er
Sta
tes)
wh
ere
th
ey
kn
ow
th
at
the
re i
s n
o c
he
ck
at
all
in
th
e c
ase
of
mil
k d
isp
en
sers
. T
his
is
sug
ge
ste
d a
s a
llo
win
g u
nfa
ir c
om
pe
titi
on
.
Fu
rth
erm
ore
, W
ELM
EC
re
ferr
ed
to
th
e p
ract
ice
of
som
e M
S t
o a
sk f
or
na
tio
na
l
cert
ific
ati
on
/ve
rifi
cati
on
fo
r th
e u
se o
f in
stru
me
nts
ju
st 2
mo
nth
s a
fte
r th
eir
pla
cin
g i
n m
ark
et
ba
sed
on
dif
fere
nt
na
tio
na
l re
gu
lati
on
s (n
ot
ha
rmo
nis
ed
). T
his
is s
ee
n a
s e
ffe
ctiv
ely
cre
ati
ng
ma
rke
t b
arr
iers
. A
t le
ast
on
e c
om
pa
ny
ag
ree
d a
nd
sta
ted
th
at
this
is a
dis
ince
nti
ve
fo
r
en
teri
ng
oth
er
ma
rke
ts.
WE
LME
C c
on
ve
no
rs s
ug
ge
ste
d t
ha
t so
me
act
ion
to
ha
rmo
niz
e a
pp
roa
ch a
mo
ng
MS
s is
ne
cess
ary
•
Tra
nsi
tio
n p
eri
od
A
cco
rdin
g t
o W
ELM
EC
WG
10
th
e t
ran
siti
on
pe
rio
d w
as
ne
cess
ary
as
on
ly f
ew
la
rge
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
85
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
com
pa
nie
s w
he
re p
rep
are
d f
or
the
MID
. M
ost
co
mp
an
ies
are
(st
ill)
no
t p
rop
erl
y i
nfo
rme
d
ev
en
if
me
cha
nis
ms
do
exi
st (
incl
ud
ing
th
e N
Bs
tha
t a
re p
rov
idin
g t
his
in
fo)
Fo
r a
t le
ast
on
e c
om
pa
ny
th
e p
rob
lem
of
the
tra
nsi
tio
n p
eri
od
is
tha
t it
pro
lon
gs
the
con
fusi
on
co
nce
rnin
g i
ssu
es
rela
ted
to
th
e c
om
bin
ati
on
of
old
an
d n
ew
in
stru
me
nts
an
d t
he
dif
fere
nt
inte
rpre
tati
on
s fr
om
no
tifi
ed
bo
die
s
Acc
ord
ing
to
an
oth
er
com
pa
ny
th
e t
ran
siti
on
pe
rio
d l
ea
ds
to a
de
lay
in
th
e u
se o
f M
ID
cert
ifie
d i
nst
rum
en
ts –
fo
r th
e t
ime
be
ing
ma
ny
co
mp
an
ies
an
d u
sers
fo
cus
on
th
e u
se o
f p
re-
MID
in
stru
me
nts
MI-
00
6 –
Au
tom
ati
c w
eig
hin
g i
nst
rum
en
ts6
3
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
Fo
r b
oth
tra
de
ass
oci
ati
on
an
d f
or
the
in
div
idu
al
ma
nu
fact
ure
rs t
he
ad
op
tio
n o
f u
nif
orm
inte
rna
tio
na
l st
an
da
rds
an
d s
ing
le c
ert
ific
ate
re
pre
sen
t a
ve
ry i
mp
ort
an
t co
ntr
ibu
tio
n o
f
the
Dir
ect
ive
th
at
ha
s le
d t
o i
mp
ort
an
t co
st s
av
ing
s.
Ho
we
ve
r, t
he
y s
tate
th
at
the
pra
ctic
al
exp
eri
en
ce c
on
cern
ing
th
e i
mp
lem
en
tati
on
of
the
MID
th
at
incl
ud
e t
he
op
era
tio
n o
f th
e n
oti
fie
d b
od
ies,
th
e m
ark
et
surv
eil
lan
ce a
nd
so
me
of
the
ad
min
istr
ati
ve
wo
rk r
eq
uir
ed
are
sti
ll p
rob
lem
ati
c.
SLO
CA
sta
ted
th
at
ma
nu
fact
ure
rs
of
AW
I h
av
e g
ive
n p
osi
tiv
e
com
me
nts
.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le
ma
rke
t
Th
e v
iew
of
CE
CIP
is
tha
t so
fa
r th
e m
ark
et
is s
till
no
t o
pe
rati
ng
in
a e
ffic
ien
t w
ay
as
a
resu
lt o
f th
e o
pti
on
ali
ty (
see
be
low
), t
he
re
stri
ctiv
e w
ay
no
tifi
ed
bo
die
s u
se W
ELM
EC
gu
ida
nce
do
cum
en
ts (
see
be
low
) a
nd
th
e f
act
th
at
som
e s
urv
eil
lan
ce a
uth
ori
tie
s te
nd
to
cre
ate
min
or
issu
es
pro
ble
ms/
ob
sta
cle
s b
y b
ein
g p
art
icu
larl
y s
tric
t in
va
rio
us
ad
min
istr
ati
ve
/bu
rea
ucr
ati
c re
qu
ire
me
nts
.
Ho
we
ve
r, a
t le
ast
on
e m
an
ufa
ctu
rer
exp
ect
ed
th
at
ov
er
tim
e t
hin
gs
sho
uld
imp
rov
e a
s
63 B
ase
d o
n i
nte
rvie
w w
ith
th
e m
ain
in
du
stry
ass
oci
ati
on
(C
EC
IP),
ma
nu
fact
ure
rs (
PE
NK
O –
SM
E (
NL)
, W
ELW
AA
RT
S-
SM
E (
NL)
, M
ett
ler
To
led
o-
Larg
e
mu
ltin
ati
on
al
(CH
),..
.).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
86
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
exp
eri
en
ce b
uil
ds
up
.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
CE
CIP
an
d c
om
pa
nie
s a
gre
e t
ha
t th
e M
ID p
rov
ide
s a
mp
le s
pa
ce f
or
tech
no
log
ica
l
inn
ov
ati
on
ba
sed
on
th
e e
sse
nti
al
req
uir
em
en
ts.
Ho
we
ve
r, C
EC
IP a
nd
in
div
idu
al
ma
nu
fact
ure
rs r
ep
ort
ed
th
at
in p
ract
ice
no
tifi
ed
bo
die
s
ten
d t
o u
se W
ELM
EC
gu
ida
nce
do
cum
en
ts “
as
if t
he
y w
ere
la
w”
, i.
e.
as
rep
rese
nti
ng
th
e
on
ly w
ay
of
con
form
ing
to
th
e r
eq
uir
em
en
ts.
As
a r
esu
lt,
ma
nu
fact
ure
rs t
ha
t d
o n
ot
foll
ow
the
m a
re a
ske
d t
o j
ust
ify
th
e r
ea
son
s fo
r n
ot
do
ing
th
at
an
d c
on
sid
er
this
as
a r
est
rict
ion
to t
he
ir c
ap
aci
ty t
o d
ev
elo
p i
nn
ov
ati
ve
so
luti
on
s.
At
lea
st o
ne
co
mp
an
y s
ug
ge
ste
d t
ha
t in
re
lati
on
to
th
e s
oft
wa
re f
or
AW
Is W
ELM
EC
do
cum
en
ts w
ere
lo
ng
, v
ery
re
stri
ctiv
e a
nd
pre
scri
pti
ve.
On
e c
om
pa
ny
re
ferr
ed
to
sp
eci
fic
case
s w
he
n t
he
no
tifi
ed
bo
dy
reje
cte
d a
sp
eci
fic
con
fig
ura
tio
n/a
pp
roa
ch t
ha
t d
id n
ot
foll
ow
th
e W
ELM
EC
ap
pro
ach
CE
CIP
re
ferr
ed
als
o t
o e
xam
ple
s
con
cern
ing
so
ftw
are
in
AW
I w
he
re
alt
ern
ati
ve
s to
th
at
pro
po
sed
by
WE
LME
C u
nd
er
mo
du
le B
ha
ve
be
en
reje
cte
d b
y n
oti
fie
d b
od
ies.
Op
tio
na
lity
- Is
it
use
d i
n t
he
sect
or
- Is
th
ere
ev
ide
nce
of
two
-tie
r
ma
rke
t
- Is
th
ere
ev
ide
nce
of
un
fair
com
pe
titi
on
Op
tio
na
lity
ha
s n
ot
be
en
use
d e
xte
nsi
ve
ly i
n t
he
se
cto
r. I
n t
hre
e c
ou
ntr
ies
(CY
, M
T,
IE)
the
re i
s n
o c
ov
era
ge
of
rail
we
igh
bri
dg
es
tha
t a
re n
ot
pre
sen
t in
th
e d
om
est
ic m
ark
et.
Ho
we
ve
r, C
EC
IP r
efe
rs t
o a
ca
se w
he
re t
he
pri
ce o
f n
on
-co
nfo
rmin
g M
Is w
as
low
er
tha
n
for
the
co
nfo
rmin
g M
Is.
It a
lso
re
ferr
ed
to
a s
pe
cifi
c co
un
try
(w
ith
ou
t p
rovi
din
g n
am
e6
4)
wh
ere
lo
cal
ma
nu
fact
ure
rs h
av
e s
up
po
rte
d o
pti
ng
ou
t in
ord
er
to m
ain
tain
co
mp
eti
tiv
e
ad
va
nta
ge
.
Sti
ll,
the
co
mp
an
ies
did
no
t se
em
to
be
pa
rtic
ula
rly
tro
ub
led
wit
h p
rob
lem
s o
f u
nfa
ir
com
pe
titi
on
or
two
tie
r m
ark
ets
.
CE
CIP
re
ferr
ed
to
a c
ase
of
a
ma
nu
fact
ure
r o
f a
uto
ma
tic
inst
rum
en
ts t
ha
t h
as
be
en
un
ab
le t
o c
om
pe
te i
n a
n
un
reg
ula
ted
ma
rke
t b
eca
use
of
the
pri
ce o
f it
s p
rod
uct
s w
hic
h
are
in
co
mp
lia
nce
wit
h t
he
MID
we
re t
oo
exp
en
siv
e w
he
n
com
pe
tin
g w
ith
pro
du
cts
no
t in
co
mp
lia
nce
du
e t
o t
he
op
tio
na
lity
.
Co
nsu
me
r p
rote
ctio
n d
ue
to o
pti
on
ali
ty a
nd
an
y
oth
er
fact
or
All
in
terv
iew
ee
s a
gre
ed
th
at
con
sum
er
pro
tect
ion
ha
s im
pro
ve
d b
eca
use
of
the
ess
en
tia
l
req
uir
em
en
ts o
f th
e M
ID.
Th
ere
wa
s n
o e
vid
en
ce o
f lo
we
r q
ua
lity
be
ing
a p
rob
lem
to
con
sum
er
pro
tect
ion
.
As
rep
ort
ed
by
tw
o c
om
pa
nie
s, d
ue
to
pro
ble
ma
tic
ma
rke
t su
rve
illa
nce
, s
om
e
com
pe
tito
rs p
rod
uce
go
lde
n p
roto
typ
es
to g
et
the
ce
rtif
ica
tio
n a
nd
th
en
bri
ng
to
th
e
64 B
ase
d o
n t
he
da
ta f
or
the
use
of
op
tio
na
lity
th
ese
co
un
trie
s ca
n b
e S
wit
zerl
an
d (
au
tom
ati
c g
rav
ime
tric
fil
lin
g i
nst
rum
en
ts)
or
UK
(a
uto
ma
tic
catc
hw
eig
he
rs)
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
87
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
ma
rke
t lo
we
r q
ua
lity
pro
du
cts
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Ov
era
ll a
re
du
ctio
n i
n t
he
to
tal
cost
s fo
r fi
rms
du
e t
o t
he
MID
is
reco
rde
d a
lth
ou
gh
wit
h
gre
at
va
ria
tio
n.
Larg
er
firm
s w
ith
pre
sen
ce i
n m
an
y m
ark
ets
be
ne
fit
mo
re.
CE
CIP
est
ima
ted
th
at
ov
era
ll a
dm
inis
tra
tiv
e b
urd
en
s h
av
e b
ee
n r
ed
uce
d g
ive
n t
he
va
lid
ity
of
cert
ific
ate
s a
rou
nd
Eu
rop
e e
ve
n i
f a
dm
inis
tra
tio
n c
ost
s a
re s
till
a s
ign
ific
an
t b
urd
en
.
Ho
we
ve
r, C
EC
IP s
ug
ge
ste
d t
ha
t th
e o
ve
rall
be
ne
fits
are
lim
ite
d c
on
cern
ing
a n
um
be
r o
f
mo
du
les
as
the
re a
re n
ow
mu
ch m
ore
exp
en
siv
e b
eca
use
of
the
str
icte
r re
qu
ire
me
nts
fo
r
the
use
of
spe
cifi
c m
od
ule
s (D
, F
) o
r b
eca
use
of
WE
LME
C g
uid
eli
ne
s fo
r m
ark
ing
.
An
oth
er
issu
e r
ais
ed
co
nce
rne
d t
ran
sla
tio
n r
eq
uir
em
en
ts u
nd
er
the
NLF
th
at
are
se
en
as
po
ssib
ly e
xce
ssiv
e.
On
e c
om
pa
ny
est
ima
ted
th
at
cost
s fo
r tr
an
sla
tio
n p
er
cou
ntr
y
exc
ee
de
d €
5,0
00
. T
wo
co
mp
an
ies
sta
ted
th
at
in t
he
ca
se o
f co
un
trie
s w
he
re t
he
y d
id n
ot
exp
ect
to
se
ll m
ore
th
an
2-3
in
stru
me
nts
an
nu
all
y,
the
y d
eci
de
d n
ot
to e
nte
r a
t a
ll.
On
e c
om
pa
ny
wit
h p
rese
nce
in
6
cou
ntr
ies
rep
ort
ed
to
tal
red
uct
ion
of
cost
s o
f €
20
,00
0-3
0,0
00
/ye
ar.
An
oth
er
com
pa
ny
wit
h p
rese
nce
in
all
27
co
un
trie
s re
ferr
ed
to
a
red
uct
ion
of
clo
se t
o 8
0%
. H
ow
ev
er,
the
y a
lso
sta
ted
th
at
the
re i
s a
ne
ed
for
mo
re c
ert
ific
ate
s fo
r e
ach
pro
du
ct f
oll
ow
ing
min
or
cha
ng
es
tha
t ca
n m
ea
n €
3,0
00
-40
00
ext
ra
cost
s fo
r a
ne
w s
yst
em
.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Ov
era
ll,
ind
ust
ry s
tak
eh
old
ers
co
nsi
de
r th
at
the
y a
re a
de
qu
ate
ly r
ep
rese
nte
d a
nd
in
clu
de
d
in t
he
pro
ced
ure
s. H
ow
ev
er,
th
ere
is a
co
nce
rn t
ha
t it
is
no
t p
oss
ible
to
fo
llo
w a
ll r
ele
va
nt
wo
rkin
g g
rou
ps
in W
ELM
EC
an
d t
o m
on
ito
r a
ll d
ocu
me
nts
pro
du
ced
. O
ne
co
mp
an
y a
ctiv
e
in W
ELM
EC
gro
up
s fe
lt t
ha
t th
eir
pa
rtic
ipa
tio
n i
s a
de
qu
ate
bu
t th
eir
in
pu
ts a
re a
lmo
st
ne
ve
r ta
ke
n i
nto
acc
ou
nt.
Imp
act
on
SM
Es
C
EC
IP p
rop
ose
d t
ha
t S
ME
s th
at
focu
s o
n a
sse
mb
lin
g c
ert
ifie
d e
qu
ipm
en
t/co
mp
on
en
ts
bo
ug
ht
fro
m o
the
r m
an
ufa
ctu
rers
an
d h
av
e t
o g
et
ad
dit
ion
al
cert
ific
ate
s fo
r th
e f
ina
l M
I
ass
em
ble
d w
ill
face
ad
dit
ion
al c
ost
s.
Fu
rth
erm
ore
, a
cco
rdin
g t
o C
EC
IP t
he
ad
dit
ion
al
tra
nsl
ati
on
co
sts
un
de
r th
e N
FL
can
be
a
dis
pro
po
rtio
na
te b
urd
en
fo
r S
ME
s if
au
tho
riti
es
req
uir
e a
ll r
ele
va
nt
do
cum
en
tati
on
.
Th
e S
ME
su
rve
y (
ba
sed
on
43
re
spo
nse
s) d
id n
ot
ind
ica
te t
he
pre
sen
ce o
f p
rob
lem
s w
ith
con
form
ity
ass
ess
me
nt
an
d n
o b
arr
iers
to
tra
de
cre
ate
d.
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts
(in
cl.
role
of
WE
LME
C)
CE
CIP
an
d c
om
pa
nie
s co
nsi
de
r th
at
the
use
of
OIM
L n
orm
ati
ve
do
cum
en
ts i
s a
de
qu
ate
as
the
y h
elp
ke
ep
Eu
rop
e i
n l
ine
wit
h t
he
re
st o
f th
e w
orl
d a
nd
he
lp e
xpo
rts.
Th
e a
bse
nce
of
Eu
rop
ea
n s
tan
da
rds
do
es
no
t p
ose
an
y p
rob
lem
Th
ere
is
a p
rob
lem
ho
we
ve
r –
acc
ord
ing
to
CE
CIP
– c
on
cern
ing
WE
LME
C g
uid
eli
ne
s th
at
are
se
en
as
too
ma
ny
an
d b
eco
min
g a
bu
rde
n.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
88
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Acc
ord
ing
to
on
e c
om
pa
ny
th
ere
is
sig
nif
ica
nt
pro
ble
m li
nke
d t
o t
he
NB
s u
sin
g W
ELM
EC
do
cum
en
ts a
re i
f th
ey
are
la
w w
hil
e f
or
an
oth
er
the
NB
s te
nd
to
ap
ply
co
nfo
rmit
y
ass
ess
me
nt
mo
du
les
in a
n i
nco
nsi
ste
nt
wa
y w
ith
va
ryin
g t
est
s.
At
lea
st t
wo
co
mp
an
ies
me
nti
on
ed
exa
mp
les
of
NB
s u
sin
g
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
Ind
ust
ry e
xpe
rie
nce
th
at
the
ma
rke
t su
rve
illa
nce
is
lim
ite
d a
nd
un
sati
sfa
cto
ry a
s in
alm
ost
all
ca
ses
au
tho
riti
es
are
lim
ite
d r
ed
uce
d t
o l
ab
els
an
d a
dm
inis
tra
tiv
e r
eq
uir
em
en
ts,
seld
om
to
th
e q
ua
lity
of
the
inst
rum
en
t.
Th
e i
mp
ort
an
t p
rob
lem
– a
s re
po
rte
d b
y t
wo
co
mp
an
ies
- is
th
at
som
e c
om
pe
tito
rs
pro
du
ce g
old
en
sa
mp
les/
pro
toty
pe
s to
ge
t th
e c
ert
ific
ati
on
an
d t
he
n b
rin
g t
o t
he
ma
rke
t
low
er
qu
ali
ty p
rod
uct
s w
ith
imp
lica
tio
n f
or
fair
co
mp
eti
tio
n a
nd
cu
sto
me
r p
rote
ctio
n.
Th
e S
ME
s su
rve
y a
lso
su
pp
ort
ed
th
e v
iew
th
at
ma
rke
t su
rve
illa
nce
is
pro
ble
ma
tic.
Aro
un
d
40
% r
efe
rre
d t
o t
he
pre
sen
ce o
f n
on
-CE
+M
ma
rke
d p
rod
uct
s co
nsi
de
red
pre
sen
tin
g u
nfa
ir
com
pe
titi
on
.
On
e c
om
pa
ny
re
po
rte
d t
ha
t in
th
e
UK
ch
eck
we
igh
ers
th
at
are
no
t M
ID-
cert
ifie
d a
re i
n c
ircu
lati
on
an
d a
re
aro
un
d 1
5%
ch
ea
pe
r.
•
Tra
nsi
tio
n p
eri
od
M
ost
co
mp
an
ies
con
sid
ere
d t
he
tra
nsi
tio
n p
eri
od
ad
eq
ua
te t
o a
llo
w s
ell
ing
th
e p
re-
exi
stin
g s
tock
.
MI-
00
7 -
Ta
xim
ete
rs6
5
Issu
es
Fin
din
gs
E
vid
en
ce/d
ata
/oth
er
info
/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
(o
ve
rall
)
Th
ree
of
fou
r m
an
ufa
ctu
rers
sta
ted
th
at
MID
ha
s so
fa
r o
ffe
red
le
ss t
ha
n w
ha
t th
ey
ho
pe
d f
or
in t
erm
s o
f a
cce
ss t
o m
ark
ets
an
d r
ed
uct
ion
of
the
ad
min
istr
ati
ve
wo
rk.
Ho
we
ve
r, t
his
is
pri
ma
rily
lin
ked
wit
h t
he
ro
le o
f n
ati
on
al/
reg
ion
al
tari
ff r
eg
ula
tio
ns
tha
t
are
no
t co
ntr
oll
ed
by
MID
(se
e b
elo
w)
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
On
e l
arg
e a
nd
tw
o S
ME
s m
an
ufa
ctu
rers
su
gg
est
ed
th
at
a s
ing
le m
ark
et
is s
till
no
t in
pla
ce d
ue
to
th
e d
iffe
ren
ces
in t
he
na
tio
na
l o
r re
gio
na
l re
gu
lati
on
s co
nce
rnin
g t
ari
ffs
(no
t co
ntr
oll
ed
by
MID
) a
nd
ta
riff
str
uct
ure
s in
ma
ny
MS
. T
his
me
an
s d
iffe
ren
t
req
uir
em
en
ts f
or
the
so
ftw
are
th
at
ne
ed
s to
be
in
teg
rate
d i
n t
he
ta
xim
ete
r a
nd
ge
t a
n
MID
ce
rtif
ica
te.
Th
is i
s se
en
pa
rtic
ula
rly
pro
ble
ma
tic
in t
he
UK
wh
ere
ov
er
40
0 l
oca
l
au
tho
riti
es
resp
on
sib
le.
Th
e m
an
ufa
ctu
rer
sta
te t
ha
t in
som
e c
ou
ntr
ies
(e.g
. U
K,
Po
rtu
ga
l)
na
tio
na
l o
r a
nd
re
gio
na
l
req
uir
em
en
ts t
en
d t
o o
pe
rate
as
pro
tect
ion
fo
r lo
cal
pro
du
cers
th
at
in s
om
e c
ase
s h
av
e p
ress
ed
lo
cal
65 B
ase
d o
n i
nte
rvie
ws
wit
h r
ep
rese
nta
tiv
es
of
fou
r m
an
ufa
ctu
rers
. (
HA
LE-
SM
E(A
U),
AQ
UIL
A-
SM
E (
UK
), D
IGIT
AX
-La
rge
(UK
), S
EM
EL-
SM
E(F
I)
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
89
Issu
es
Fin
din
gs
E
vid
en
ce/d
ata
/oth
er
info
/
ex
am
ple
s
Ma
nu
fact
ure
rs s
tate
d t
ha
t if
th
ey
wa
nt
to a
cce
ss m
ore
th
an
on
e m
ark
et
ne
ed
to
inte
gra
te a
ll t
ari
ff r
eq
uir
em
en
ts (
wh
ich
are
no
t M
ID r
eg
ula
ted
) to
th
e t
axi
me
ter’
soft
wa
re f
rom
th
e b
eg
inn
ing
(o
ne
co
mp
an
y s
aw
th
at
as
a p
osi
tiv
e i
nce
nti
ve
) o
r g
et
ad
dit
ion
al
cert
ific
ate
s fo
r e
ve
ry c
ha
ng
e m
ad
e.
On
e c
om
pa
ny
re
po
rte
d t
ha
t it
wa
s
ess
en
tia
lly
no
t a
llo
we
d t
o e
nte
r a
no
the
r m
ark
et
du
e t
o t
his
pro
tect
ion
alt
ho
ug
h a
no
the
r
SM
E d
id c
on
sid
er
tha
t a
s a
n i
ssu
e.
au
tho
riti
es
for
intr
od
uci
ng
ne
w
req
uir
em
en
ts.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Ne
ith
er
for
mo
st f
irm
s M
ID h
as
cre
ate
d o
bst
acl
es
no
r h
as
it p
lay
ed
a s
tro
ng
ro
le i
n
sup
po
rtin
g i
nn
ov
ati
on
. H
ow
ev
er,
on
e c
om
pa
ny
sta
ted
th
at
the
use
of
a s
ing
le E
U
cert
ific
ate
wa
s a
ctu
all
y a
po
siti
ve
in
cen
tiv
e f
or
de
ve
lop
ing
a n
ew
EU
wid
e t
yp
e t
axi
me
ter
an
d a
no
the
r th
at
the
re
qu
ire
me
nt
of
soft
wa
re s
ep
ara
tio
n (
leg
al
an
d n
on
-le
ga
l p
art
) is
po
siti
ve
in
th
e s
en
se t
ha
t is
cre
ate
d a
n i
nce
nti
ve
fo
r in
no
va
tio
n.
In c
on
tra
st,
the
ma
in i
ssu
es/
ob
sta
cle
s fo
r th
e d
ev
elo
pm
en
t o
f n
ew
ta
xim
ete
rs c
om
e
fro
m t
he
na
tio
na
l ta
riff
re
gu
lati
on
s. M
ore
sp
eci
fica
lly
th
e r
eq
uir
em
en
ts c
on
cern
ing
taxi
me
ter
dis
pla
ys
or
the
mu
ltip
le a
nd
dif
fere
nt
tari
ff s
tru
ctu
res
we
re s
ee
n a
s re
stri
ctiv
e.
Op
tio
na
lity
- Is
it
use
d i
n t
he
sect
or
- Is
th
ere
ev
ide
nce
of
two
-tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
co
mp
eti
tio
n
Op
tio
na
lity
ha
s b
ee
n u
sed
in
on
ly t
wo
co
un
trie
s (N
O,
CH
) w
he
re t
he
re i
s a
tw
o t
ier
ma
rke
t re
po
rte
d b
y m
an
ufa
ctu
rers
ba
sed
on
th
e i
mp
ort
of
che
ap
old
ta
xim
ete
rs f
rom
oth
er
cou
ntr
ies.
Th
e C
A o
f N
orw
ay
did
no
t co
nsi
de
r th
at
the
be
ne
fits
to
co
nsu
me
rs
just
ifie
d t
he
co
sts
of
imp
osi
ng
re
gu
lati
on
. T
he
fo
cus
of
au
tho
riti
es
is o
n r
eg
ula
tin
g a
nd
che
ckin
g t
he
ta
riff
s a
s th
is is
se
en
as
the
im
po
rta
nt
issu
e f
or
con
sum
ers
.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
Co
nsu
me
r p
rote
ctio
n i
s ,
acc
ord
ing
to
in
du
stry
, su
b-o
pti
ma
l as
ma
rke
t su
rve
illa
nce
in
som
e M
S i
s p
art
ial
or
ev
en
no
n-e
xist
en
t (s
ee
be
low
) a
llo
win
g f
or
all
ty
pe
s o
f n
on
-
con
form
ing
ta
xim
ete
rs p
rod
uce
d b
y l
oca
l p
rod
uce
rs w
ith
no
MID
ce
rtif
ica
te t
o e
nte
r th
e
ma
rke
t. A
ga
in,
CA
s d
o n
ot
con
sid
er
tha
t co
nsu
me
r p
rote
ctio
n i
s li
nk
ed
wit
h t
he
MID
req
uir
em
en
ts c
on
cern
ing
ta
xim
ete
rs a
s ta
riff
str
uct
ure
s a
nd
oth
er
issu
es
con
cern
ing
ta
xi
dri
ve
rs a
nd
co
nsu
me
rs a
re r
eg
ula
ted
at
the
na
tio
na
l o
r lo
cal
lev
el.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Co
mp
an
ies
sta
te t
ha
t th
ere
are
gre
ate
r co
sts
rela
ted
to
th
e u
se o
f so
me
of
the
mo
du
les
for
con
form
ity
ass
ess
me
nt.
Tim
e r
eq
uir
ed
wa
s o
ve
r a
ye
ar
alt
ho
ug
h e
xpe
ct t
his
to
be
less
in
th
e f
utu
re.
On
e c
om
pa
ny
me
nti
on
ed
th
e
cert
ific
ati
on
is
4-5
tim
es
mo
re
exp
en
siv
e i
n t
ota
l in
co
mp
ari
son
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
90
Issu
es
Fin
din
gs
E
vid
en
ce/d
ata
/oth
er
info
/
ex
am
ple
s
Sti
ll,
bo
th t
he
la
rge
an
d m
ed
ium
siz
e f
irm
s su
gg
est
ed
th
at
the
ad
va
nta
ge
de
riv
ed
fro
m
the
ca
pa
city
to
acc
ess
mo
re t
ha
n o
ne
ma
rke
t w
ith
on
e c
ert
ific
ate
ou
twe
igh
s th
e c
ost
s.
wit
h p
rev
iou
s p
eri
od
– i
ncl
ud
ing
lon
ge
r w
ait
ing
pe
rio
d a
nd
ass
oci
ate
d c
ost
s.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Th
ere
is
no
bo
dy
(a
sso
cia
tio
n)
rep
rese
nti
ng
ta
xim
ete
rs' m
an
ufa
ctu
rers
. In
div
idu
al
ma
nu
fact
ure
rs a
re i
n g
en
era
l u
na
ble
to
co
mm
un
ica
te t
he
ir c
on
cern
s a
nd
pro
ble
ms.
Sti
ll,
the
in
terv
iew
ed
co
mp
an
ies
did
no
t se
em
to
co
nsi
de
r it
as
a p
art
icu
larl
y im
po
rta
nt
pro
ble
m
Imp
act
on
SM
Es
N
o s
pe
cifi
c is
sue
s w
ere
ra
ise
d d
uri
ng
th
e i
nte
rvie
ws
wh
ile
th
e S
ME
su
rve
y i
nd
ica
ted
th
at
the
re a
re n
o b
arr
iers
to
tra
de
be
cau
se o
f th
e M
ID.
In t
he
UK
an
d s
om
e o
the
r co
un
trie
s,
loca
l m
an
ufa
ctu
rers
co
mp
ete
in
lo
cal
ma
rke
ts b
ase
d o
n n
ati
on
al/
reg
ion
al
req
uir
em
en
ts
an
d a
bse
nce
of
ma
rke
t su
rve
illa
nce
. A
t le
ast
in
th
e U
K,
the
ce
rtif
ica
tio
n c
ost
s a
re s
ee
n
as
pa
rtic
ula
rly
hig
h f
or
SM
Es.
A U
K c
om
pa
ny
sta
ted
£3
0,0
00
(€3
5,0
00
) in
to
tal
for
init
ial
cert
ific
ati
on
fo
llo
win
g m
od
ule
s B
+D
an
d £
6,0
00
(€
7,0
00
) fo
r a
nn
ua
l
rev
iew
of
mo
du
le D
(q
ua
lity
co
ntr
ol
syst
em
).
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts (
incl
.
role
of
WE
LME
C)
Acc
ord
ing
to
th
e i
nte
rvie
ws
the
re a
re n
o a
gre
ed
sta
nd
ard
s u
sed
(a
lth
ou
gh
th
ere
are
OIM
L r
eco
mm
en
da
tio
ns
an
d r
esp
ect
ive
WE
LME
C g
uid
an
ce d
ocu
me
nts
). T
he
La
tvia
n
CA
sta
ted
th
at
the
re a
re n
o s
tan
da
rds
an
d t
his
is
see
n a
s a
pro
ble
m f
or
ma
nu
fact
ure
rs.
On
e c
om
pa
ny
co
nsi
de
red
th
at
WE
LME
C d
ocs
are
he
lpfu
l
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Ma
nu
fact
ure
rs r
ep
ort
ed
in
con
sist
en
cie
s a
mo
ng
no
tifi
ed
bo
die
s in
re
lati
on
to
th
e
inte
rpre
tati
on
of
the
ess
en
tia
l re
qu
ire
me
nts
an
d t
he
te
stin
g m
eth
od
s. O
ne
co
mp
an
y
wa
s a
fra
id t
ha
t th
e s
tric
t in
terp
reta
tio
n i
n N
ord
ic c
ou
ntr
ies
is n
ot
foll
ow
ed
in
oth
ers
.
Fu
rth
erm
ore
, m
an
ufa
ctu
rers
re
po
rt t
ha
t te
sts
by
no
tifi
ed
bo
die
s te
nd
to
ta
ke
a v
ery
lon
g t
ime
(m
ore
th
an
1 y
ea
r).
(exp
eri
en
ce s
ug
ge
sts
tha
t p
riva
te o
ne
s a
re f
ast
er
bu
t le
ss
tho
rou
gh
, p
ub
lic
on
es
are
ext
rem
ely
th
oro
ug
h b
ut
slo
w a
nd
in s
om
e c
ase
s in
de
cisi
ve
)
An
oth
er
com
pa
ny
(S
ME
) su
gg
est
ed
th
at
the
co
sts
of
cert
ific
ati
on
are
ra
the
r h
igh
an
d
cre
ate
dis
ince
nti
ve
fo
r in
tro
du
cin
g f
req
ue
nt
cha
ng
es.
Ho
we
ve
r, t
his
wa
s n
ot
a c
om
mo
n
vie
w.
Fu
rth
erm
ore
, o
ne
SM
E r
ep
ort
ed
th
at
the
ma
in n
oti
fie
d b
od
y i
n F
ran
ce c
he
cke
d f
or
ad
dit
ion
al
issu
es
rela
ted
to
th
e n
ati
on
al
reg
ula
tio
n a
nd
eff
ect
ive
ly c
rea
ted
ba
rrie
r to
en
ter
the
sp
eci
fic
ma
rke
t.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
91
Issu
es
Fin
din
gs
E
vid
en
ce/d
ata
/oth
er
info
/
ex
am
ple
s
• M
ark
et
surv
eil
lan
ce b
y
au
tho
riti
es
All
co
mp
an
ies
sta
ted
th
at
ma
rke
t su
rve
illa
nce
is
pro
ble
ma
tic
an
d t
ha
t it
va
rie
s g
rea
tly
.
In t
he
UK
an
d F
I it
is
rep
ort
ed
th
at
the
re i
s a
lmo
st n
o s
urv
eil
lan
ce.
Th
e S
ME
s su
rve
y
fro
m P
ort
ug
al
an
d S
pa
in i
nd
ica
ted
th
e p
rese
nce
of
un
ma
rke
d t
axi
me
ters
th
at
com
pe
te
in t
he
do
me
stic
ma
rke
t.
On
e m
an
ufa
ctu
rer
sug
ge
ste
d t
ha
t
de
spit
e c
on
tin
uo
us
req
ue
sts
to
the
au
tho
riti
es,
in
ess
en
ce t
he
re
is n
o s
urv
eil
lan
ce o
f th
e m
ark
et
in
the
UK
an
d t
ha
t ta
xim
ete
rs
pro
du
ced
by
lo
cal
ma
nu
fact
ure
rs
wit
h n
o c
ert
ific
ati
on
an
d n
o C
E
ma
rkin
g a
re c
ircu
late
d i
n t
he
ma
rke
t66.
•
Tra
nsi
tio
n p
eri
od
T
he
co
mp
an
ies
con
sid
ere
d t
ha
t th
e t
ran
siti
on
pe
rio
d c
ou
ld b
e s
ho
rte
r b
ut
this
did
no
t
ap
pe
ar
to p
lay
a p
art
icu
lar
po
siti
ve
or
ne
ga
tiv
e r
ole
.
Oth
er
S
om
e t
axi
me
ter
pro
du
cers
pro
po
sed
th
at
MID
ess
en
tia
l re
qu
ire
me
nts
sh
ou
ld b
e
ext
en
de
d t
o c
ov
er
mo
re t
ari
ffs
an
d t
o b
e m
ore
sp
eci
fic
in t
erm
s o
f th
e t
yp
es
of
tari
ffs
all
ow
ed
in
ord
er
to a
dd
ress
th
e p
rob
lem
s o
f a
dd
itio
na
l n
ati
on
al/
reg
ion
al
reg
ula
tio
n.
In t
he
co
nte
xt o
f W
ELM
EC
wo
rkin
g g
rou
ps
the
iss
ue
of
the
in
clu
sio
n o
f d
ista
nce
sig
na
l
ge
ne
rato
rs a
s su
b-a
sse
mb
lie
s h
as
be
en
ra
ise
d b
ut
it i
s n
ot
sup
po
rte
d b
y a
ll C
As.
It
is
als
o p
rop
ose
d t
ha
t m
ore
de
tail
ed
sp
eci
fica
tio
ns
of
the
ma
xim
um
pe
rmis
sib
le e
rro
r fo
r
the
re
al
tim
e c
lock
of
taxi
me
ters
are
ne
cess
ary
.
MI-
00
8a
– T
ap
es/
Dip
stic
ks6
7
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r
info
/ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
Th
e c
om
pa
nie
s in
terv
iew
ed
su
gg
est
ed
th
at
the
re h
av
e n
ot
be
en
an
y p
art
icu
lar
cha
ng
es
or
66 T
He
UK
CA
ack
no
wle
dg
e t
his
pro
ble
m a
nd
sta
te t
ha
t th
e m
ain
re
aso
n i
s th
e a
bse
nce
of
inte
rna
l e
xpe
rtis
e,
reso
urc
es
an
d c
ap
aci
ty i
n t
he
De
pa
rtm
en
t o
f
Tra
nsp
ort
. T
he
y a
re i
nte
nd
ing
to
ad
dre
ss i
t b
ut
cou
ld n
ot
ind
ica
te a
tim
eta
ble
.
67 B
ase
d o
n i
nte
rvie
w w
ith
th
e r
ep
rese
nta
tiv
e o
f m
an
ufa
ctu
rers
:EN
RA
F-
Ho
ne
yw
ell
(F
R).
Fis
che
r-D
are
x O
uti
lla
ge
(im
po
rte
r fr
om
Ta
iwa
n t
o F
ran
ce),
To
olv
izio
n
Inte
rna
tio
na
l (N
L) a
nd
co
mm
en
ts f
rom
Eu
rop
ea
n H
an
d T
oo
ls a
sso
cia
tio
n (
CE
O).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
92
imp
lem
en
tati
on
of
the
Dir
ect
ive
be
ne
fits
wit
h t
he
ne
w r
eg
ime
an
d t
ha
t it
is
ve
ry m
uch
bu
sin
ess
as
usu
al
wit
h o
nly
ch
an
ge
s in
na
me
s. S
till
acc
ord
ing
to
CE
O t
he
ma
in a
nd
re
al
be
ne
fit
for
its
me
mb
ers
ha
s b
ee
n t
he
act
ua
l
red
uct
ion
of
ba
rrie
rs b
y t
he
use
of
a s
ing
le c
ert
ific
ate
acr
oss
EU
. M
ain
be
ne
fits
co
nce
rne
d t
he
qu
ali
ty s
ea
l th
at
the
CE
ma
rk p
rovi
de
s w
hil
e m
ino
r is
sue
s co
nce
rn t
he
lo
ng
er
tim
e f
or
the
cert
ific
ati
on
pro
cess
an
d n
ee
d f
or
fre
qu
en
t u
pg
rad
e o
f ce
rtif
ica
te f
or
soft
wa
re.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
Tw
o l
ow
-te
ch c
om
pa
nie
s st
ate
d d
id n
ot
con
sid
er
MID
wa
s n
ot
as
imp
ort
an
t fo
r th
eir
pro
du
cts
giv
en
th
eir
fo
cus
on
th
e d
om
est
ic m
ark
et.
Ho
we
ve
r a
hig
he
r-te
chn
olo
gy
co
mp
an
y s
ug
ge
ste
d
tha
t it
he
lpe
d e
nte
r n
ew
EU
ma
rke
ts a
nd
th
e C
EO
sta
ted
th
at
all
its
me
mb
ers
co
nsi
de
red
th
at
the
MID
did
in
de
ed
he
lp c
rea
te a
sin
gle
ma
rke
t th
at
is o
pe
rati
ng
qu
ite
eff
ect
ive
ly.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Tw
o c
om
pa
nie
s in
terv
iew
ed
su
gg
est
ed
no
t re
al
eff
ect
of
the
MID
as
the
ir p
rod
uct
s a
re r
ath
er
sta
nd
ard
an
d l
ow
te
ch.
Fo
r th
e o
ne
co
mp
an
y p
rod
uci
ng
mo
re a
dv
an
ced
te
chn
olo
gy
inst
rum
en
ts w
ith
so
ftw
are
, th
e m
ain
pro
ble
m i
s th
at
ev
en
sm
all
so
ftw
are
ch
an
ge
s n
ee
d t
o b
e
ap
pro
ve
d.
Th
is w
as
see
n a
s ti
me
co
nsu
min
g a
nd
co
stly
.
Op
tio
na
lity
- Is
it
use
d i
n t
he
sect
or
- Is
th
ere
ev
ide
nce
of
two
-tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
co
mp
eti
tio
n
Op
tio
na
lity
wa
s u
sed
in
5 c
ou
ntr
ies
be
cau
se t
he
y w
ere
no
t re
gu
late
d b
efo
re a
nd
th
at
the
re
wa
s n
ot
pe
rce
ive
d n
ee
d.
On
e m
an
ufa
ctu
rer
sug
ge
ste
d t
ha
t th
ey
we
re a
wa
re o
f so
me
sm
all
fir
ms
tha
t d
o n
ot
ha
ve
th
e
CE
ma
rk a
nd
so
ld a
t lo
we
r p
rice
s. S
till
, th
ey
did
no
t se
e t
he
m a
s co
mp
eti
ng
in
th
e s
am
e
ma
rke
t– t
he
y m
ain
ly s
ell
on
la
rge
sca
le t
o h
yp
erm
ark
ets
.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
Ma
nu
fact
ure
rs d
id n
ot
con
sid
er
tha
t th
ere
wa
s m
ajo
r/im
po
rta
nt
iss
ue
wit
h t
he
se p
rod
uct
s
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Th
e c
om
pa
nie
s d
id n
ot
ind
ica
te i
mp
ort
an
t ch
an
ge
s a
nd
hig
he
r co
sts
in c
om
pa
riso
n t
o t
he
pre
-
MID
re
gim
e a
nd
giv
en
th
eir
pre
sen
ce i
n o
nly
on
e m
ark
et
the
y d
id n
ot
exp
eri
en
ce s
ign
ific
an
t
dif
fere
nce
s. O
ne
co
mp
an
y (
EN
RA
F)
sta
ted
th
ou
gh
th
at
cert
ific
ati
on
te
nd
s to
ta
ke
a b
it –
bu
t
no
t cr
itic
all
y -
lo
ng
er
tha
n i
n t
he
pa
st.
Acc
ord
ing
to
on
e c
om
pa
ny
cost
s fo
r th
e p
roce
ss r
an
ge
d
be
twe
en
€3
-5k
.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Mo
st c
om
pa
nie
s w
ere
no
t a
wa
re o
f th
e p
rese
nce
of
the
wo
rkin
g g
rou
p b
ut
did
no
t se
em
to
con
sid
er
the
ir a
bse
nce
an
iss
ue
.
Imp
act
on
SM
Es
T
he
re w
as
no
ev
ide
nce
pro
vid
ed
fro
m a
ny
so
urc
e t
ha
t S
ME
s e
xpe
rie
nce
d a
dd
itio
na
l im
pa
cts
du
e t
o t
he
MID
. T
he
SM
E s
urv
ey
in
dic
ate
d t
ha
t co
nfo
rmit
y a
sse
ssm
en
t p
roce
du
res
we
re
ad
eq
ua
te f
or
ov
er
75
% o
f th
e f
irm
s a
ctiv
e i
n t
he
se
cto
r a
nd
on
ly 1
5%
of
the
co
mp
an
ies
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
93
refe
rre
d t
o p
rese
nce
of
ba
rrie
rs t
o t
rad
e.
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts
(in
cl.
role
of
WE
LME
C)
Th
e u
se o
f O
IML
sta
nd
ard
s in
th
e c
ase
of
hig
h-t
ech
pro
du
cts
is s
ee
n a
s a
de
qu
ate
an
d d
oe
s n
ot
cre
ate
an
y p
rob
lem
s. T
he
re i
s n
o a
dd
ed
va
lue
ass
ign
ed
to
WE
LME
C f
rom
th
e m
an
ufa
ctu
rers
sid
e.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Co
mp
an
ies
did
no
t in
dic
ate
ch
an
ge
s in
co
mp
ari
son
to
th
e p
ast
an
d d
id n
ot
refe
r to
an
y
pro
ble
ms.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
Th
e c
om
pa
nie
s d
id n
ot
ind
ica
te a
ny
pro
ble
ms
in r
ela
tio
n t
o m
ark
et
surv
eil
lan
ce a
nd
at
lea
st
on
e o
f th
em
wa
s p
osi
tiv
e t
ha
t p
rod
uct
s w
ith
ou
t C
E+
M m
ark
are
no
t a
llo
we
d i
n t
he
ma
rke
t,
wh
ich
wa
s co
nsi
de
red
su
ffic
ien
t. H
ow
ev
er,
th
e S
ME
su
rve
y r
esp
on
ses
ind
ica
ted
th
at
the
pre
sen
ce o
f n
on
-CE
ma
rke
d l
en
gth
me
asu
rin
g i
nst
rum
en
ts t
ha
t, a
cco
rdin
g t
o t
he
ma
jori
ty
con
stit
ute
d u
nfa
ir c
om
pe
titi
on
. H
ow
ev
er
,it
is n
ot
cle
ar
wh
eth
er
refe
ren
ce w
as
ma
de
on
ly t
o
MIs
use
d f
or
leg
al
me
tro
log
y p
urp
ose
s
•
Tra
nsi
tio
n p
eri
od
It
wa
s n
ot
con
sid
ere
d a
s e
ith
er
too
lo
ng
or
too
sh
ort
tw
o c
om
pa
nie
s b
ut
use
ful
for
a m
ore
hig
h-t
ech
co
mp
an
y.
MI-
00
8b
– C
ap
aci
ty s
erv
ing
me
asu
res6
8
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r
info
/ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
(o
ve
rall
)
Th
e c
om
pa
nie
s su
gg
est
ed
th
at
the
re w
ere
no
sig
nif
ica
nt
dif
fere
nce
s w
ith
th
e p
re-M
ID
situ
ati
on
an
d t
ha
t th
ey
co
uld
no
t re
po
rt p
art
icu
lar
pro
ble
ms
or
issu
es
fro
m t
he
imp
lem
en
tati
on
of
the
Dir
ect
ive
. P
erc
eiv
ed
qu
ali
ty f
rom
th
e C
E-m
ark
wa
s se
en
as
a b
en
efi
t b
ut
oth
erw
ise
th
ere
we
re n
ot
ma
jor
issu
es.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
MID
in
tro
du
ctio
n is
no
t se
en
as
ha
vin
g p
lay
ed
an
y i
mp
ort
an
t ro
le f
or
the
co
mp
an
ies
tha
t h
av
e
lim
ite
d e
xpo
rts
an
d w
he
re a
lre
ad
y u
sin
g q
ua
lity
sy
ste
ms.
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
All
co
mp
an
ies
inte
rvie
we
d s
ug
ge
ste
d t
ha
t th
ere
is
no
ro
le o
n t
ech
no
log
ica
l in
no
va
tio
n a
s th
e
ind
ust
ry is
lo
w t
ech
.
Op
tio
na
lity
- Is
it
use
d i
n t
he
Op
tio
na
lity
ha
s b
ee
n u
sed
in
a n
um
be
r o
f co
un
trie
s (5
) a
s ca
pa
city
se
rvin
g m
ea
sure
s w
ere
no
t
see
n a
s a
pro
ble
m a
rea
th
at
ha
d t
o b
e r
eg
ula
ted
.
68 B
ase
d o
n i
nte
rvie
w w
ith
th
e r
ep
rese
nta
tiv
e o
f th
ree
ma
nu
fact
ure
rs:
Mit
che
l &
Co
op
er
(Mu
ltin
ati
on
al)
, In
vict
a P
last
ics
(UK
), F
isch
er-
Da
rex-
Ou
tila
ge
(im
po
rt
fro
m T
aiw
an
to
Fra
nce
) a
nd
on
e t
rad
e F
EV
E (
Eu
rop
ea
n G
lass
Co
nta
ine
rs A
sso
cia
tio
n).
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
94
sect
or
(ho
w m
an
y
MS
an
d w
hy
)
- Is
th
ere
ev
ide
nce
of
two
-tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
co
mp
eti
tio
n
Tw
o t
ier
ma
rke
ts d
o e
xist
bu
t C
As
did
no
t se
e t
ha
t a
s a
pro
ble
m.
Co
mp
an
ies
did
no
t h
av
e
exp
eri
en
ce o
f p
rob
lem
s.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
No
ma
jor
issu
es
rep
ort
ed
in
re
lati
on
to
th
e o
pti
on
ali
ty.
On
e i
ssu
e s
tate
d f
rom
on
e c
om
pa
ny
in
the
UK
is
tha
t th
e u
nd
er
MID
pla
stic
gla
sse
s th
at
are
usu
all
y ch
ea
pe
r ca
n s
till
be
MID
ce
rtif
ied
de
spit
e t
ha
t fa
ct t
ha
t th
ey
ma
y n
ot
be
as
acc
ura
te b
eca
use
th
ey
ca
n b
e b
en
t d
uri
ng
th
e
serv
ing
.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Tw
o c
om
pa
nie
s d
id n
ot
con
sid
er
tha
t th
ere
we
re s
ub
sta
nti
al
cha
ng
es
an
d g
ive
n t
ha
t th
ey
we
re
focu
sin
g o
n d
om
est
ic m
ark
et
the
re w
ere
als
o li
mit
ed
be
ne
fits
.
Th
e t
hir
d r
efe
rre
d t
o t
he
ne
ed
fo
r ch
an
ge
of
the
ye
ar
in t
he
sta
mp
ing
to
ol
as
the
on
ly m
arg
ina
l
incr
ea
se i
n t
he
ad
min
istr
ati
ve
co
sts.
FE
VE
– b
ase
d o
n c
om
me
nts
fro
m m
an
ufa
ctu
rers
- a
lso
rep
ort
ed
th
ese
co
sts
are
re
lati
ve
ly im
po
rta
nt
bu
t a
lso
me
nti
on
ed
an
in
cre
ase
in
ov
era
ll c
ost
s
for
do
cum
en
tati
on
.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Ma
nu
fact
ure
rs w
ere
no
t fa
mil
iar
wit
h t
he
wo
rkin
g g
rou
p a
nd
th
e o
the
r re
pre
sen
tati
on
me
cha
nis
ms
bu
t d
id n
ot
ide
nti
fy p
art
icu
lar
rea
son
s fo
r b
ein
g a
ctiv
ely
en
ga
ge
d.
Imp
act
on
SM
Es
N
o s
pe
cifi
c d
iffe
ren
ces
be
twe
en
SM
Es
an
d l
arg
e c
om
pa
nie
s w
ere
id
en
tifi
ed
. T
he
sm
all
nu
mb
er
of
firm
s in
th
e S
ME
su
rve
y a
ctiv
e i
n t
he
se
cto
r (6
) in
dic
ate
d n
o b
arr
iers
to
tra
de
an
d n
o
pro
ble
ms
wit
h c
on
form
ity
ass
ess
me
nt.
Tw
o o
f th
e 6
sta
ted
ho
we
ve
r th
e p
rese
nce
of
un
fair
com
pe
titi
on
.
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts
(in
cl.
role
of
WE
LME
C)
No
iss
ue
re
po
rte
d.
Th
e c
om
pa
nie
s su
gg
est
ed
th
at
the
y a
re e
asy
to
me
et
an
d n
ot
ve
ry d
iffe
ren
t
fro
m t
he
pa
st.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
No
iss
ue
/pro
ble
ms
we
re r
ep
ort
ed
by
an
y o
f th
e i
nte
rvie
we
es
in t
he
ir r
ela
tio
n w
ith
th
e n
oti
fie
d
bo
die
s.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
No
iss
ue
re
po
rte
d.
At
lea
st i
n r
ela
tio
n t
o t
he
UK
, co
mp
an
ies
sug
ge
ste
d t
ha
t su
rve
illa
nce
wa
s
ad
eq
ua
te a
nd
no
n-m
ark
ed
pro
du
cts
are
no
t a
llo
we
d t
o c
ircu
late
.
•
Tra
nsi
tio
n p
eri
od
T
he
tra
nsi
tio
n p
eri
od
wa
s co
nsi
de
red
ap
pro
pri
ate
alt
ho
ug
h n
on
e o
f th
e c
om
pa
nie
s su
gg
est
ed
an
y r
ea
l n
ee
d o
f it
.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
95
MI-
00
9 –
Dim
en
sio
na
l m
ea
suri
ng
in
stru
me
nts
69
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
No
sig
nif
ica
nt
issu
es/
pro
ble
ms
we
re r
ep
ort
ed
by
ma
nu
fact
ure
rs t
ha
t st
ate
d l
imit
ed
ch
an
ge
s
fro
m t
he
pre
vio
us
reg
ime
bu
t re
cog
nis
ed
th
e p
osi
tiv
e r
ole
of
a s
ing
le c
ert
ific
ate
. F
rom
th
e
ne
ga
tiv
e s
ide
, fo
r m
ore
co
mp
lica
ted
/hi-
tech
MIs
th
at
incl
ud
e s
oft
wa
re t
he
re a
re a
dd
itio
na
l
cost
s a
s e
ve
ry t
ime
th
ere
is
ne
w v
ers
ion
th
ere
is
ne
ed
fo
r u
pd
ati
ng
th
e c
ert
ific
ate
.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
Acc
ord
ing
to
all
co
mp
an
ies,
th
e i
mp
lem
en
tati
on
of
the
Dir
ect
ive
ha
s h
elp
ed
eli
min
ate
so
me
na
tio
na
l b
arr
iers
th
at
exi
ste
d b
efo
re.
All
co
mp
an
ies
con
sid
er
the
sin
gle
ce
rtif
ica
te a
s
sup
po
rtin
g e
ntr
y i
n o
the
r m
ark
ets
an
d r
efe
rre
d t
o a
ctu
al
be
ne
fits
in
te
rms
of
sale
s.
No
sp
eci
fic
exa
mp
les
of
be
ne
fits
giv
en
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
Fo
r lo
we
r te
ch p
rod
uct
s, t
he
Dir
ect
ive
ha
s a
ne
utr
al
eff
ect
.
In t
he
ca
se o
f m
ore
co
mp
lica
ted
pro
du
cts
- e
spe
cia
lly
wh
en
th
ere
is
soft
wa
re i
nv
olv
ed
- t
he
re
is a
pro
ble
m s
ince
th
ey
ne
ed
to
go
th
rou
gh
th
e c
ert
ific
ati
on
pro
cess
wh
en
a c
ha
ng
e i
s m
ad
e o
r
ne
w f
un
ctio
ns
are
ad
de
d.
Th
is,
acc
ord
ing
to
on
e c
om
pa
ny
, d
ela
ys
inn
ov
ati
on
cy
cle
.
On
e m
an
ufa
ctu
rer
refe
rre
d a
lso
to
th
e c
ase
of
inst
rum
en
ts t
ha
t co
mb
ine
dis
tan
ce a
nd
we
igh
t
for
wh
ich
th
ey
fe
lt t
he
y w
ere
no
t co
ve
red
by
th
e M
ID a
nd
th
at
the
y n
ee
de
d t
o s
ep
ara
te
cert
ific
ati
on
. T
his
wa
s se
en
as
inh
ibit
ing
th
eir
in
teg
rati
on
in
to a
sin
gle
me
asu
rin
g i
nst
rum
en
t
Op
tio
na
lity
- Is
it
use
d i
n t
he
sect
or
- Is
th
ere
ev
ide
nce
of
two
-tie
r m
ark
et
- Is
th
ere
ev
ide
nce
of
un
fair
co
mp
eti
tio
n
Op
tio
na
lity
ha
s b
ee
n w
ide
ly u
sed
(9
co
un
trie
s) a
s M
S d
id n
ot
con
sid
er
ne
cess
ary
to
re
gu
late
to
en
sure
co
nsu
me
r p
rote
ctio
n a
nd
en
forc
em
en
t a
nd
co
mp
lia
nce
co
sts
wo
uld
ou
twe
igh
an
y
be
ne
fits
.
Fro
m t
he
sid
e o
f th
e m
an
ufa
ctu
rers
it
wa
s su
gg
est
ed
th
at
eit
he
r th
ey
we
re n
ot
aw
are
of
un
ma
rke
d p
rod
uct
s co
mp
eti
ng
or
the
y w
ere
no
t co
nce
rne
d b
y t
his
co
mp
eti
tio
n a
s th
ey
we
re
in d
iffe
ren
t m
ark
et
seg
me
nts
.
Co
nsu
me
r p
rote
ctio
n d
ue
to
op
tio
na
lity
an
d a
ny
oth
er
fact
or
No
iss
ue
s/e
xpe
rie
nce
s re
po
rte
d.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
All
ma
nu
fact
ure
rs s
ug
ge
ste
d t
ha
t th
ere
is
mo
re a
dm
inis
tra
tiv
e w
ork
loa
d,
pa
pe
rwo
rk i
nv
olv
ed
,
an
d t
ha
t th
e p
roce
ss o
f ce
rtif
ica
tio
n t
en
ds
to t
ak
e l
on
ge
r. S
till
, o
ve
rall
th
ey
als
o a
gre
ed
th
at
the
be
ne
fits
of
imp
rov
ed
ma
rke
t a
cce
ss o
utw
eig
he
d t
he
co
sts
On
e c
om
pa
ny
est
ima
ted
th
at
foll
ow
ing
an
in
itia
l
inv
est
me
nt
for
eq
uip
me
nt
69 B
ase
d o
n i
nte
rvie
w w
ith
th
e r
ep
rese
nta
tiv
e o
f fo
ur
ma
nu
fact
ure
rs:
Vit
ron
ic (
DE
), M
etr
ie (
CZ
), K
ab
elm
at
(DE
), F
ISC
O (
UK
)
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
96
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
a
nd
tra
inin
g o
f a
rou
nd
€1
1m
it w
ou
ld s
av
e a
rou
nd
€1
1m
an
nu
all
y.
An
oth
er
refe
rre
d t
o a
to
tal
du
rati
on
of
the
pro
cess
of
up
to 9
mo
nth
s in
to
tal,
mo
re
tha
t in
th
e p
ast
.
Re
pre
sen
tati
on
in
th
e
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
Fir
ms
we
re u
na
wa
re o
f th
e C
om
mit
tee
bu
t d
id n
ot
ind
ica
te a
ne
ed
to
be
re
pre
sen
ted
.
Imp
act
on
SM
Es
T
he
in
terv
iew
s d
id n
ot
ind
ica
te t
he
pre
sen
ce o
f sp
eci
fic
imp
act
s to
SM
Es
be
cau
se o
f th
e M
ID.
Th
e S
ME
su
rve
y r
esu
lts
– i
ncl
ud
ing
40
fir
ms
act
ive
in
th
e s
ect
or
– i
nd
ica
te t
he
pre
sen
ce o
f
lim
ite
d m
ark
et
surv
eil
lan
ce t
ha
t is
se
en
as
cau
sin
g u
nfa
ir c
om
ple
tio
n (
32
% o
f fi
rms)
bu
t, in
ge
ne
ral,
no
ba
rrie
rs t
o t
rad
e (
aro
un
d 7
3%
sta
ted
) a
nd
on
ly o
ne
re
ferr
ed
to
pro
ble
ms
wit
h
con
form
ity
ass
ess
me
nt
pro
ced
ure
s.
Pa
ram
ete
rs/f
act
ors
aff
ect
ing
im
ple
me
nta
tio
n
•
Ro
le o
f st
an
da
rds
an
d
gu
ida
nce
do
cum
en
ts
Th
ere
are
no
iss
ue
s ra
ise
d b
y t
he
in
terv
iew
ee
s in
re
lati
on
to
th
e u
se o
f st
an
da
rds.
Tw
o l
ow
-te
ch c
om
pa
nie
s w
ere
un
aw
are
of
WE
LME
C w
hil
e t
he
mo
re h
igh
-te
ch i
nd
ica
ted
th
at
WE
LME
C d
ocu
me
nts
we
re u
sefu
l.
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
Th
ere
are
no
iss
ue
s o
r p
rob
lem
s re
po
rte
d a
nd
th
e f
irm
s su
gg
est
ed
th
at
the
y h
av
e o
ve
rall
be
en
ve
ry h
elp
ful
in g
ett
ing
ce
rtif
ica
tio
n w
ith
ou
t m
ajo
r is
sue
s. H
ow
ev
er,
on
e U
K c
om
pa
ny
sta
ted
tha
t th
ere
is
a s
ho
rta
ge
of
ve
rifi
cati
on
/te
stin
g l
ab
ora
tori
es
an
d o
f a
pp
rop
ria
tely
sk
ille
d l
ab
s.
Th
is h
old
s b
ack
th
e a
pp
rov
al
pro
cess
.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
All
co
mp
an
ies
con
sid
ere
d t
ha
t th
ere
we
re n
o i
ssu
es
or
pro
ble
ms
con
cern
ing
ma
rke
t
surv
eil
lan
ce.
•
Tra
nsi
tio
n p
eri
od
C
om
pa
nie
s su
gg
est
ed
th
at
it w
as
ap
pro
pri
ate
an
d o
ne
of
the
m t
ho
ug
ht
it w
as
ne
cess
ary
to
pla
n p
rod
uct
ion
ch
an
ge
s.
Oth
er
O
ne
co
mp
an
y s
tate
d t
ha
t it
is
rath
er
cost
ly t
o p
ut
CE
in
ea
ch i
nd
ivid
ua
l M
I a
s th
ey
are
usu
all
y
sold
wh
ole
sale
. C
urr
en
tly
CE
ma
rk i
s p
lace
d b
y b
atc
h w
ith
th
e w
ho
lesa
ler
ho
ldin
g t
he
cert
ific
ate
bu
t th
ey
we
re u
ncl
ea
r w
he
the
r th
is f
oll
ow
ed
MID
re
qu
ire
me
nts
.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
97
MI-
01
0 –
Ex
ha
ust
ga
s a
na
lyze
rs7
0
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
Exp
eri
en
ce f
rom
th
e
imp
lem
en
tati
on
of
the
Dir
ect
ive
Acc
ord
ing
to
EG
EA
th
e i
nd
ust
ry i
s p
osi
tiv
e f
rom
th
e i
mp
lem
en
tati
on
of
the
Dir
ect
ive
as
it
ha
s m
ad
e m
uch
ea
sie
r, l
ess
co
st i
nte
nsi
ve
an
d l
ess
bu
rea
ucr
ati
c th
e p
laci
ng
of
EG
As
in
the
Me
mb
er
Sta
tes
ma
rke
t.
In t
he
UK
, th
ere
is
lim
ite
d e
xpe
rie
nce
. T
he
UK
ga
rag
e e
qu
ipm
en
t a
sso
cia
tio
n w
ith
re
fere
nce
to
on
ly
6 u
nit
s a
pp
rove
d d
uri
ng
th
e la
st 4
ye
ars
. S
o f
ar,
pro
du
cts
de
ve
lop
ed
be
fore
th
e e
ntr
y o
f th
e M
ID
into
fo
rce
are
so
ld in
th
e m
ark
et.
De
ve
lop
me
nt
of
an
eff
icie
nt
op
era
tin
g s
ing
le m
ark
et
Acc
ord
ing
to
on
e m
an
ufa
ctu
rer
the
ma
in b
arr
ier
to t
he
de
ve
lop
me
nt
of
an
eff
icie
nt
sin
gle
ma
rke
t is
th
e f
act
th
at
insp
ect
ion
ce
ntr
es
(th
e o
nly
bu
ye
rs f
or
EG
As)
re
qu
ire
bu
yin
g b
oth
EG
As
an
d s
mo
ke
-me
ters
to
ge
the
r. A
s sm
ok
e-m
ete
rs a
re n
ot
incl
ud
ed
in
th
e
MID
an
d s
till
re
qu
ire
na
tio
na
l ap
pro
va
l th
e M
ID h
as
stil
l n
o e
ffe
ct i
n t
his
re
spe
ct.
Th
is i
s
sup
po
rte
d b
y E
GE
A t
ha
t su
gg
est
th
at
the
no
n-c
ov
era
ge
Te
chn
olo
gic
al
inn
ov
ati
on
-
sup
po
rtin
g/h
am
pe
rin
g
EG
EA
co
nsi
de
rs t
ha
t th
e c
urr
en
t le
gis
lati
on
on
te
st p
roce
du
res
lim
it i
nn
ov
ati
on
fo
r
ma
nu
fact
ure
rs
Acc
ord
ing
to
GE
A t
he
Dir
ect
ive
did
no
t in
tro
du
ce c
ha
ng
es
in t
he
ess
en
tia
l re
qu
ire
me
nts
as
it a
do
pte
d t
he
OIM
L re
qu
ire
me
nts
. T
he
on
ly d
iffe
ren
ce c
on
cern
ed
th
e s
tric
ter
req
uir
em
en
ts f
or
the
se
ali
ng
of
soft
wa
re a
ga
inst
ta
mp
eri
ng
wh
ich
ha
s n
ot
bro
ug
ht
imp
ort
an
t ch
an
ge
s.
Th
e M
ID d
oe
s n
ot
cov
er
the
pro
cess
no
r th
e s
oft
wa
re n
ece
ssa
ry f
or
EG
A b
ut
on
ly t
he
me
asu
rin
g i
nst
rum
en
t it
self
. M
an
ufa
ctu
rers
th
us
stil
l n
ee
d t
o r
ece
ive
na
tio
na
l a
pp
rova
l
for
the
ir i
nst
rum
en
ts.
Op
tio
na
lity
- Is
it
use
d i
n t
he
se
cto
r
- Is
th
ere
ev
ide
nce
of
two
-tie
r
ma
rke
t
- Is
th
ere
ev
ide
nce
of
un
fair
com
pe
titi
on
Acc
ord
ing
to
EG
EA
op
tio
na
lity
ha
s n
ot
be
en
use
d i
n t
he
sp
eci
fic
sect
or.
Ho
we
ve
r, d
ata
fro
m W
ELM
EC
in
dic
ate
th
ree
co
un
trie
s (D
K,
MT
an
d A
ust
ria
).
Co
nsu
me
r p
rote
ctio
n d
ue
to
E
nd
-use
rs a
re t
he
MO
T c
en
tre
s ra
the
r th
an
co
nsu
me
rs.
Th
ey
are
no
t a
ffe
cte
d s
ince
70 B
ase
d o
n i
nte
rvie
w w
ith
tw
o t
rad
e a
sso
cia
tio
ns,
EG
EA
(re
pre
sen
tin
g g
as
an
aly
zers
ma
nu
fact
ure
rs,
the
UK
Ga
rag
e E
qu
ipm
en
t A
sso
cia
tio
n -
GE
A (
rep
rese
nti
ng
use
rs o
f g
as
an
aly
zers
) a
nd
on
e m
an
ufa
ctu
rer.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
98
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
op
tio
na
lity
an
d a
ny
oth
er
fact
or
op
tio
na
lity
ha
s n
ot
be
en
use
d i
n t
his
se
cto
r.
MID
, in
co
mb
ina
tio
n w
ith
Dir
ect
ive
20
09
/40
EC
, h
as
set
qu
ali
ty l
ev
el
an
d s
tan
da
rds
for
ga
s-te
ste
rs a
nd
ra
ise
d t
he
qu
ali
ty l
ev
el
in t
he
ma
rke
t.
Evi
de
nce
of
two
-tie
r m
ark
et
an
d
un
fair
co
mp
eti
tio
n d
ue
to
op
tio
na
lity
an
d o
the
r fa
cto
rs
Acc
ord
ing
to
GE
A g
as
an
aly
sers
fo
r M
OT
s71 i
n t
he
UK
ha
ve
to
be
ce
rtif
ied
an
d a
pp
rov
ed
an
d r
ep
rese
nt
80
% o
f th
e U
K m
ark
et.
Fo
r th
e r
em
ain
ing
20
% u
sed
in
ga
rag
es
the
re a
re
no
sim
ila
r te
sts
bu
t th
ere
is
no
exp
eri
en
ce a
s to
wh
eth
er
the
re i
s u
nfa
ir c
om
pe
titi
on
.
Ad
min
istr
ati
ve
bu
rde
ns
cre
ate
d/r
ed
uce
d
Acc
ord
ing
to
EG
EA
wh
ile
th
e i
nit
ial
ad
min
istr
ati
ve
in
ve
stm
en
t h
as
incr
ea
sed
, th
e e
ffo
rt
for
mo
st c
om
pa
nie
s d
ue
th
e u
se o
f si
ng
le c
ert
ific
ate
. I
n t
he
UK
, th
e n
ati
on
al
ass
oci
ati
on
sug
ge
sts
the
re i
s a
dd
itio
na
l re
d t
ap
e f
or
an
aly
sers
to
be
use
d a
t M
OT
s (8
0%
of
the
ma
rke
t) a
s in
ste
ad
of
rep
laci
ng
th
e M
ID c
ert
ific
ati
on
ad
de
d o
ne
mo
re s
tep
. A
dd
itio
na
l
test
s b
y s
ep
ara
te l
ab
ora
tori
es
are
sti
ll r
eq
uir
ed
.
Fro
m t
he
pro
du
ctio
n s
ide
on
e m
an
ufa
ctu
rer
sta
ted
th
at
the
in
tro
du
ctio
n o
f M
od
ule
D
an
d s
ub
seq
ue
nt
surv
eil
lan
ce a
ud
its
incr
ea
sed
co
sts
bu
t co
uld
no
t a
sse
ss i
f th
e b
en
efi
t
fro
m a
sin
gle
ce
rtif
ica
te w
as
gre
ate
r o
r n
ot.
Th
e U
K i
mp
act
ass
ess
me
nt
est
ima
tes
ad
min
istr
ati
ve
bu
rde
ns
at
aro
un
d £
5,0
00
(€6
,00
0)
pe
r a
nn
um
fo
r
ma
nu
fact
ure
rs.
Re
pre
sen
tati
on
of
sta
ke
ho
lde
rs
in t
he
Me
asu
rin
g i
nst
rum
en
ts
com
mit
tee
an
d W
ELM
EC
Th
e i
nd
ust
ry h
as
no
t b
ee
n r
ep
rese
nte
d i
n t
he
me
asu
rin
g i
nst
rum
en
ts c
om
mit
tee
or
in
WE
LME
C.
EG
EA
exp
ress
ed
wil
lin
gn
ess
to
be
mo
re a
ctiv
ely
inv
olv
ed
an
d e
xpre
sse
d
con
cern
th
at
it h
as
no
t re
ceiv
ed
su
ch i
nv
ita
tio
n in
th
e p
ast
.
Imp
act
on
SM
Es
A
cco
rdin
g t
o E
GE
A t
he
eff
ect
of
cutt
ing
re
d t
ap
e a
nd
re
du
cin
g a
dm
inis
tra
tiv
e b
urd
en
is
imp
ort
an
t fo
r o
ur
com
pa
nie
s, w
ho
are
ty
pic
all
y S
ma
ll a
nd
Me
diu
m s
ize
d E
nte
rpri
ses
(SM
Es)
.
Acc
ord
ing
to
on
e l
arg
e m
an
ufa
ctu
rer
the
bu
rde
n o
n s
ma
ll b
usi
ne
sse
s is
no
t
pro
po
rtio
na
tely
gre
ate
r th
an
fo
r la
rge
bu
sin
ess
es
aft
er
an
in
itia
l p
eri
od
of
fam
ilia
risa
tio
n.
Th
e S
ME
su
rve
y i
ncl
ud
ing
17
fir
ms
act
ive
in
th
e s
ect
or
ind
ica
ted
th
at
the
re a
re n
ot
pro
ble
ms
wit
h t
he
co
nfo
rmit
y a
sse
ssm
en
t (n
o f
irm
sta
ted
pro
ble
ms)
an
d o
nly
on
e
refe
rre
d t
o t
he
pre
sen
ce o
f b
arr
iers
to
tra
de
. T
he
ma
jori
ty s
tate
d t
ha
t th
ere
are
no
n
CE
+M
ma
rke
d p
rod
uct
s in
th
e m
ark
et
– m
ain
ly a
mo
ng
ne
w M
em
be
r S
tate
s –
bu
t o
nly
2
tho
ug
ht
tha
t th
ey
co
nst
itu
ted
un
fair
co
mp
eti
tio
n.
•
Ro
le o
f st
an
da
rds
an
d
Th
e u
se o
f th
e O
IML
no
rma
tive
do
cum
en
ts h
as
be
en
in
lin
e w
ith
th
e s
tan
da
rds
use
d b
y
71
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Me
asu
rin
g I
nst
rum
en
ts a
na
lysi
s ta
ble
s
E
99
Issu
es
F
ind
ing
s
Ev
ide
nce
/da
ta/o
the
r in
fo/
ex
am
ple
s
gu
ida
nce
do
cum
en
ts
MO
Ts
for
ap
pro
va
l o
f a
na
lyse
rs a
nd
th
ere
ha
ve
be
en
no
pro
ble
ms
to t
his
po
int.
On
e m
an
ufa
ctu
rer
un
de
rlin
ed
th
e u
sefu
lne
ss o
f W
ELM
EC
;’s
do
cum
en
tati
on
, e
spe
cia
lly
reg
ard
ing
th
e t
ran
smis
sio
n b
etw
ee
n i
nst
rum
en
ts a
nd
so
ftw
are
•
Imp
lem
en
tati
on
by
no
tifi
ed
bo
die
s
On
e c
om
pa
ny
in
Ita
ly is
usi
ng
PT
B f
or
Mo
du
le B
be
cau
se t
he
y h
av
e a
lo
ng
exp
eri
en
ce
wit
h i
t. M
od
ule
D h
as
be
en
do
ne
wit
h N
Mi
Ne
the
rla
nd
s b
eca
use
th
ey
ha
ve
th
e I
tali
an
bra
nch
wh
ich
av
oid
ed
a l
ot
of
do
cum
en
t tr
an
sla
tio
n.
EG
A i
s a
ne
w b
usi
ne
ss a
nd
ap
pro
va
ls a
re s
till
re
lati
ve
ly r
ece
nt.
T
he
re i
s n
o e
xpe
rie
nce
to
co
mp
are
wit
h f
rom
pre
vio
us
exp
eri
en
ces.
Th
is c
om
pa
ny
ha
s o
nly
en
tere
d
the
EG
s m
ark
et
in 2
00
0
na
tio
na
lly
an
d i
n 2
00
5 i
n
an
oth
er
cou
ntr
y.
•
Ma
rke
t su
rve
illa
nce
by
au
tho
riti
es
Acc
ord
ing
to
GE
A t
he
re h
as
be
en
lim
ite
d m
ark
et
surv
eil
lan
ce f
rom
th
e n
ati
on
al
au
tho
riti
es
in t
he
UK
co
nce
rnin
g g
as
an
aly
sers
. H
ow
ev
er,
in
th
e c
ase
of
MO
T t
est
ing
faci
liti
es
tha
t re
pre
sen
t a
rou
nd
80
% o
f th
e t
ota
l m
ark
et
MID
ce
rtif
ica
te i
s a
re
qu
ire
me
nt
in a
dd
itio
n t
o o
the
r re
qu
ire
me
nts
se
t.
•
Tra
nsi
tio
n p
eri
od
T
he
tra
nsi
tio
n p
eri
od
do
es
no
t se
em
to
po
se a
ny
pro
ble
ms.
Oth
er
T
he
re a
re q
ue
stio
ns
rais
ed
by
EG
EA
, a
ma
nu
fact
ure
r a
nd
at
lea
st o
n C
A (
DE
) a
s to
th
e
lim
ite
d c
ov
era
ge
of
ga
s a
na
lyse
rs b
y t
he
MID
. A
cco
rdin
g t
o E
GE
A I
t is
in
con
sist
en
t, t
ha
t
the
pe
tro
l p
art
of
an
an
aly
zer
is c
ov
ere
d b
y t
he
MID
, w
he
rea
s th
e d
iese
l sm
ok
e p
art
is
no
t re
qu
irin
g a
se
pa
rate
na
tio
na
l ce
rtif
ica
tio
n.
Th
is f
act
ha
s li
mit
ed
th
e a
cce
pta
nce
of
the
MID
, b
eca
use
ma
nu
fact
ure
rs h
av
e t
o g
et
na
tio
na
l a
pp
rov
als
fo
r th
e d
iese
l p
art
. T
hu
s a
the
in
clu
sio
n o
f a
‘d
iese
l’ r
ela
ted
re
qu
ire
me
nt
is s
ee
n a
s n
ece
ssa
ry.
Inte
rim
Ev
alu
ati
on
of
the
Me
asu
rin
g I
nst
rum
en
ts D
ire
ctiv
e –
Fin
al
rep
ort
Ap
pe
nd
ix
Op
tio
na
lity
use
by
Me
mb
er
Sta
tes
F
10
0